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U.S. Consumer Product Safety Commission (CPSC)

Call 305-456-3830 or email info@diaztradelaw.com.

Mandatory CPSC eFiling is Here

Key Takeaways 

  • Starting July 8, 2026, importers of most regulated consumer products must electronically file (eFile) Certificate of Compliance data into CBP’s ACE system at the time of entry, no longer on request. 
  • At launch, CPSC does not intend to have ACE reject entries or deny admission solely for failure to eFile, only warning messages. But CPSC will still enforce certificate requirements, seek seizure of non-compliant goods, and adjust your risk score. 
  • A testing exemption or determination does not eliminate the certificate. You must still issue a certificate citing the rule and naming the exemption. This is a trap that catches importers who assume “exempt” means “nothing to file.” 
  • Products entering a Foreign Trade Zone and later withdrawn for consumption or warehousing get a later effective date: January 8, 2027. 
  • The eFiling rule changes how certificate data is filed, not which products need a certificate. Certification has been required since 2008. 

A Compliance Shift Disguised as a Filing Update

Since 2008, importers and domestic manufacturers of CPSC-regulated consumer products have been required to maintain a Certificate of Compliance: a Children’s Product Certificate (CPC) for children’s products, or a General Certificate of Conformity (GCC) for regulated general-use products, and produce it on request. Under […]

By |2026-07-08T10:11:26-04:00July 8, 2026|ACE, Import, U.S. Consumer Product Safety Commission (CPSC)|0 Comments
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The CPSC eFiling Deadline is Right Around the Corner!  

Summary: On December 18, 2024, the CPSC voted to approve a Final Rule requiring importers of regulated consumer products to electronically file Certificate of Compliance data at the time of entry. The rule takes effect July 8, 2026, for most imported consumer products. This article covers what the CPSC eFiling requirement means for importers, and the steps businesses should take now to ensure compliance before the deadline. 

On July 8, 2026, the CPSC’s mandatory eFiling requirements take effect for most imported consumer products. That means importers can no longer wait to be asked for a Certificate of Compliance. These certificates must now be electronically filed in CBP’s Automated Commercial Environment (ACE) at the time of entry, not after the fact.  

Importers that are not compliant with the applicable effective date may experience delays in the release of their shipments and increased scrutiny by CPSC at the port of entry. For products entering from a Foreign Trade Zone, the compliance date is January 8, 2027. 

CPSC’s eFiling Proposal 

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for the eFiling of certificate data for regulated […]

By |2026-06-30T19:04:46-04:00June 18, 2026|ACE, Import, Pre-compliance, U.S. Consumer Product Safety Commission (CPSC), U.S. Customs and Border Protection (CBP)|0 Comments
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CIT Hands Down $3.4M Penalty for Duty Evasion

On July 18, 2025, the Court of International Trade (CIT) granted the government’s motion for default judgment against importer Rayson Global and its owner, Doris Cheng, for negligently failing to pay duties. 

The Case

The government’s case was filed in 2023, alleging that the importers had falsely declared that Chinese-origin goods as Thai origin to evade duties. The government asserted this false declaration avoided payment of ordinary 6% duties, Section 301 duties ranging from 10% to 25%, and 234.51% antidumping duties. 

The government asked the court to impose a penalty for negligence. The penalty amount is twice the loss of revenue or the domestic value, whichever is lower. After the importer failed to answer the complaint (a huge mistake), the U.S. moved for summary judgment.

The CIT granted the government’s motion and ordered the importer to pay a nearly $3.4 million penalty as well as all unpaid duties, taxes, and cash deposits on the unliquidated entries in question.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies are turning to creative or outright illegal strategies to reduce their tariff liability.

These incentives have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount […]

By |2025-07-25T10:16:59-04:00July 25, 2025|Enforcement, Import, International Trade, penalty, Reasonable Care, U.S. Consumer Product Safety Commission (CPSC), U.S. Department of Justice (DOJ)|0 Comments
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CPSC Approves Final Rule to Implement eFiling for Certificates of Compliance

The CPSC voted unanimously in favor of a Final Rule to implement electronic filing (eFiling) of Certificate information for regulated, imported consumer products.

The new eFiling program will apply to all imported consumer products subject to a mandatory safety standard, including de minimis shipments. Requirements impacting most imported consumer products and those produced domestically will take effect in July 2026.

Background – CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the test with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing the expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at the time of import.

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule implementing the eFiling proposal.

eFiling Requirements

The eFiling rule will impose new requirements for how importers manage product certificate data, not which products require a certificate. Any consumer product that is subject to a CPSC […]

By |2025-07-02T14:13:01-04:00December 19, 2024|U.S. Consumer Product Safety Commission (CPSC)|0 Comments
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CPSC’s Upcoming eFiling Requirement: What You Need to Know

The Consumer Product Safety Commission (CPSC) is tasked with protecting the public from unreasonable risks of injury or death associated with consumer products. The agency issues and enforces standards, issues product recalls, researches hazardous products, and more. The agency also has the authority to order the detention and seizure of goods that it believes to be non-compliant with CPSC safety regulations.

Beginning in 2025, products regulated by the CPSC may be denied entry into the U.S. unless the importer electronically files a detailed product certification with Customs and Border Protection (CBP).

See a full list of CPSC regulated products here.

CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the text with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at import.

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule […]

By |2024-11-30T10:29:56-05:00November 30, 2024|U.S. Consumer Product Safety Commission (CPSC)|0 Comments
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