Certificates of Compliance
Published Date: 1/8/2025
Rule
Summary
Starting July 8, 2026, importers, manufacturers, and private labelers of CPSC-regulated products must file their Certificates of Compliance electronically with U.S. Customs. This new rule makes the process smoother and matches other safety testing rules. Products entering from foreign trade zones have until January 8, 2027, to follow the new electronic filing system—helping keep products safe and paperwork easy!
Analyzed Economic Effects
7 provisions identified: 2 benefits, 5 costs, 0 mixed.
Must eFile Certificates with CBP
If you import, manufacture, or private-label CPSC-regulated finished products that must be certified, you must eFile certificate data with U.S. Customs (CBP). This eFiling requirement becomes effective July 8, 2026 (and January 8, 2027 for products entered from foreign trade zones).
De minimis Shipments Must Use ET86
Low-value (de minimis) shipments that contain CPSC-regulated finished products must use an ACE entry type capable of transmitting CPSC's PGA Message Set (currently ET86) so the certificate data can be sent to CBP and CPSC.
International Mail Requires Pre-Arrival Registry Entry
For CPSC-regulated products imported by international mail, importers must enter certificate data into CPSC's Product Registry before the shipment arrives in the United States so CPSC staff can analyze the data and help target mail inspections.
Product Registry Filing Options Provided
CPSC's Product Registry lets certifiers submit certificate data via a Full or Reference PGA Message Set using a web UI, batch CSV upload, or an API. Brokers or designated third parties can submit data on behalf of a certifier.
Importer of Record Holds Legal Responsibility
The rule places legal responsibility for issuing finished product certificates on the Importer of Record (IOR) eligible to make entry under the Tariff Act; an authorized broker may identify the owner, purchaser, or consignee as the party responsible in the PGA Message Set.
Five-Year Certificate Recordkeeping Rule
Finished product certifiers must keep required testing and certification records for five years from the date of creation.
Component Part Certificates Voluntary
The Final Rule clarifies that component part certificates are voluntary and that the requirement to certify applies to finished products; each certificate must describe a single product.
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