US / CPSC / Import Compliance
From 8 July 2026, importers of CPSC-regulated consumer products must transmit Certificate of Compliance data through CBP's Automated Commercial Environment at the time of entry — a GCC or CPC filed electronically, not a paper copy kept on file. Foreign-trade-zone entries get until 8 January 2027.
Last updated 17 August 2026
CPSC's Final Rule revising 16 CFR Part 1110, approved 18 December 2024 and published in the Federal Register on 8 January 2025, requires Certificate of Compliance data for CPSC-regulated imports to be transmitted electronically to CBP through the CPSC Partner Government Agency (PGA) Message Set in the Automated Commercial Environment (ACE), at the time of entry. A certificate that exists only as a paper document or PDF held on file is no longer enough — the data itself has to be filed with the shipment. The rule is effective 8 July 2026 for most entries, and 8 January 2027 for products imported into a foreign-trade zone and later entered for consumption or warehousing.
Source: Federal Register, "Certificates of Compliance" (2024-30826); CPSC Final Rule, 16 CFR Part 1110.
Under the Full PGA Message Set, every certificate data element is submitted through ACE with each individual shipment. Under the Reference PGA Message Set, the certificate is entered once into CPSC's Product Registry and a reference ID is transmitted through ACE for every later shipment of that same, unchanged product — the more efficient route for anyone importing the same SKU repeatedly rather than a one-off consignment.
Source: Covington & Burling, "Clock's Ticking: Less Than Six Months to Prepare for CPSC eFiling"; CPSC, eFiling FAQ.
CPSC has flagged roughly 600 HTS codes where at least half the products typically require a GCC or CPC, or that carry special enforcement interest. From 8 July 2026, a shipment filed under one of those codes without complete certificate data triggers an electronic warning at entry — this is targeted, not a blanket customs slowdown, so knowing whether your product's HTS code is on that list is worth checking before your first post-deadline shipment, not after.
Source: GDLSK, "New CPSC eFiling Rule for Imported Consumer Products".
Non-compliance carries civil penalties of roughly $120,500 per violation under CPSC's current penalty schedule. The less obvious cost is what happens after: a compliance failure permanently raises the importer's CBP risk score, which means more frequent inspection holds on future, unrelated shipments — a one-time paperwork gap that keeps costing money at the border long after it's fixed.
Source: Stinson LLP, "Get Your Certificates Ready for the CPSC eFiling Rule".
8 July 2026 for most CPSC-regulated consumer products entered for consumption or warehousing. Products and substances imported into a foreign-trade zone and later entered for consumption or warehousing get an extra six months, to 8 January 2027.
Certificate of Compliance data — a General Certificate of Conformity (GCC) for general-use products or a Children's Product Certificate (CPC) for children's products — must be transmitted electronically through CBP's Automated Commercial Environment (ACE) via the CPSC Partner Government Agency (PGA) Message Set, at the time of entry. Paper or PDF certificates kept on file are no longer sufficient on their own.
Under the Full PGA Message Set, all certificate data elements are submitted through ACE with every shipment. Under the Reference PGA Message Set, the certificate is entered once into CPSC's Product Registry and a reference ID is transmitted through ACE for each subsequent shipment of that same product — more efficient for importers who repeatedly bring in an unchanged product.
CPSC has flagged roughly 600 HTS codes where at least half of the products typically require a GCC or CPC, or that carry special enforcement interest. From 8 July 2026, a shipment under one of those codes without complete certificate data can trigger an electronic warning at entry, and non-compliance carries civil penalties of roughly $120,500 per violation plus a lasting hit to the importer's CBP risk score, meaning more frequent holds on future shipments.
Most importers of consumer electronics have a Certificate of Compliance on file somewhere — the gap is getting that data into the Full or Reference PGA Message Set correctly, before the shipment is at the border. We check whether your product's HTS code is on CPSC's flagged list, set up Product Registry entries for repeat SKUs, and fold eFiling readiness into the rest of your US market-access work.
Book a scoping call