Imports · CPSC eFiling

eFiling for children's products (2026): what changed

Last verified October 21, 2026 · General information, not legal advice

Short answer: Since July 8, 2026, importers of children's products, and of other CPSC-regulated products that need a certificate, must electronically file (eFile) the certificate data with U.S. Customs and Border Protection when the entry is filed in ACE. Products entered from a Foreign Trade Zone follow on January 8, 2027. CPSC says eFiling creates no new testing or certification obligations and does not apply to US manufacturers: it changes how the CPC data you already need reaches CPSC.

Last verified: October 21, 2026. General information, not legal advice. KidsTestingLabs is an independent directory and guide: we don't test products and never issue or certify Children's Product Certificates. The US importer or US manufacturer is responsible for certifying compliance.

Timeline

What changed, and when?

Dates from the Federal Register and CPSC.

  1. Dec 18, 2024

    CPSC approves the final rule revising 16 CFR part 1110 (certificates of compliance) and adding eFiling.

    Approved

  2. Jan 8, 2025

    Final rule published in the Federal Register (90 FR 1800).

    Published

  3. Sept 24, 2025

    Technical correction: one effective date for the rule, July 8, 2026, with separate applicability dates. No change to compliance dates.

    Corrected

  4. Jul 8, 2026

    eFiling is mandatory for imported regulated consumer products, including children's products, de minimis shipments and mail imports.

    In effect

  5. Jan 8, 2027

    Products imported into a Foreign Trade Zone and then entered for consumption or warehousing must be eFiled too.

    Starts Jan 8, 2027

Sources: CPSC news release 26-604 (July 8, 2026): mandatory eFiling in effect, CPSC news release 25-068 (Dec 18, 2024): final eFiling rule approved, Federal Register, Jan 8, 2025: Certificates of Compliance final rule (90 FR 1800), Federal Register, Sept 24, 2025: Certificates of Compliance correction (dates). Last verified: October 21, 2026.

Who files

Who has to eFile?

The finished product certifier, which for imports is normally the importer of record.

  • The importer. For eFiling, the importer is the Importer of Record (IOR): an owner, purchaser or authorized customs broker eligible to make entry.
  • If a broker is the IOR and doesn't know enough about the product to be responsible for testing and certification, the broker may name the owner, purchaser or consignee who hired it as the party responsible for the certificate data.
  • You can rely on someone else to enter the data (for example in CPSC's Product Registry), but the certifier stays legally responsible for the certificate's validity, accuracy, completeness and availability (16 CFR 1110.15).
  • Mail imports: the certificate data must be entered in CPSC's Product Registry before the product arrives in the US.
  • De minimis shipments are covered. CPSC will not typically treat a consumer buying for personal use as the importer responsible for certification.
  • US manufacturers don't eFile. They still issue the certificate on or before the date the product is distributed and must produce it within 24 hours if CPSC asks.

Sources: CPSC: eFiling resources for importers, eCFR: 16 CFR part 1110 (certificates of compliance), CPSC news release 26-604 (July 8, 2026): mandatory eFiling in effect. Last verified: October 21, 2026.

Data elements

What data goes into an eFiled certificate?

The same content a CPC already needs, under 16 CFR 1110.11.

ElementWhat you provide
1. Product identificationAt least one unique identifier (GTIN, model number, SKU, UPC, serial or registered number, or an alternate identifier) plus enough description to match the product to the certificate
2. Each rule certified toEvery applicable consumer product safety rule, ban, standard or regulation, listed separately
3. The certifierName, street address, city, state or province, country, email and phone of the party certifying compliance
4. Records contactName and contact details of the person keeping the test records; a position title is allowed if it's always staffed
5. Manufacture date and placeMonth and year at minimum, plus the manufacturer's name, address, email and phone
6. Testing date and placeMost recent test date, and name and contact details of each CPSC-accepted lab the certificate relies on
7. AttestationFor eFiled certificates, the attestation is built into the Product Registry and CPSC's message set

Source: eCFR: 16 CFR part 1110 (certificates of compliance) (sections 1110.11 and 1110.13). Last verified: October 21, 2026. Our free CPC builder lays out the same seven elements.

How it works

How does eFiling actually happen?

The data is filed in CBP's Automated Commercial Environment (ACE) when the entry is filed (or the entry and entry summary, if filed together), in the format set by CPSC's PGA Message Set implementation guide (CATAIR). CPSC's Product Registry is a CPSC database built to make submitting those data elements easier; importers usually create the Product Registry business account, and an IOR gives its CBP-assigned IOR number when it does.

  • An eFiled certificate must be in English (16 CFR 1110.9).
  • Each certificate describes only one product (16 CFR 1110.13(a)).
  • You still give the certificate to each distributor and retailer, and produce it within 24 hours if CPSC or CBP asks (16 CFR 1110.13(b), (c)).
  • Keep certificates and supporting test records for at least five years from the certificate date (16 CFR 1110.17).
  • Component part certificates are not eFiled when a component is imported (16 CFR 1110.19).

Sources: eCFR: 16 CFR part 1110 (certificates of compliance), CPSC: eFiling resources for importers, CPSC: Product Registry account. Last verified: October 21, 2026.

What didn't change

Does eFiling add new tests?

No. CPSC says it only modernizes how certificate data is sent.

Still required

  • Third-party testing by a CPSC-accepted lab
  • A Children's Product Certificate for each product
  • Tracking labels on product and packaging
  • Periodic retesting

What's new

  • CPC data filed electronically at entry
  • Mail imports: data in the Product Registry before arrival
  • FTZ entries from January 8, 2027

CPSC: eFiling "creates no new testing, certification, or compliance obligations" and "does not apply to domestic manufacturers" (CPSC news release, July 8, 2026). Last verified: October 21, 2026.

Checklist

What should an importing seller do now?

A practical order of steps. Your customs broker confirms the filing details.

  • Confirm who is the importer of recordYou, your freight forwarder or your customs brokerFirst
  • Make sure each SKU has a current CPCBacked by a passing report from a CPSC-accepted labRequired
  • Set up the Product Registry accountUsually by the importer; IORs give their IOR numberSetup
  • Agree with your broker how certificate data is filedIn ACE with each entry, using CPSC's message setEach entry
  • Keep records for five yearsCertificates and supporting test recordsOngoing

General information, not legal advice. KidsTestingLabs doesn't file customs entries and never issues or certifies CPCs. Our done-for-you service prepares a CPC draft with the data elements above for you to review and sign.

FAQ

Frequently asked questions

Is CPSC eFiling mandatory now?

Yes. Since July 8, 2026, importers of regulated consumer products, including children's products, must eFile certificate data with CBP at entry. Products entered from a Foreign Trade Zone follow on January 8, 2027.

Do I need to eFile if I make my products in the US?

No. CPSC says eFiling does not apply to domestic manufacturers. You still issue a certificate on or before the date the product is distributed and must make it available within 24 hours if CPSC asks.

Does eFiling apply to de minimis or mail shipments?

Yes. The rule covers products claiming the de minimis duty exemption. For products imported by mail, the certificate data must be entered in CPSC's Product Registry before the product arrives.

If my customs broker files, who is responsible?

The finished product certifier. You may rely on another party to enter data, but under 16 CFR 1110.15 the certifier remains legally responsible for the certificate's accuracy, completeness and availability.

Does eFiling mean extra testing?

No. CPSC says eFiling creates no new testing, certification or compliance obligations. You still need tests from a CPSC-accepted lab and a CPC for each product.

Can KidsTestingLabs eFile for me?

No. We don't file customs entries and never issue or certify CPCs. Our done-for-you service prepares a CPC draft with the data elements eFiling needs, for you to review and sign.

Next step

Need a CPC or a lab report?

Our free CPC builder lays out all 7 required elements. No report yet? Estimate your test cost in a minute, then we'll send your product to up to 3 CPSC-accepted labs for quotes.

Sources

Official sources we checked

Checked October 21, 2026. Rules and marketplace policies change; confirm on the source before you act.