The Consumer Safety Product Commission (CPSC) is scheduled to further automate its process for authorizing the release of merchandise imported into the United States that may be subject to CPSC regulations and requirements beginning sometime in early 2025. The CPSC will implement a more in-depth electronic filing (eFiling) system that will require importers to transmit certain data to the U.S. Customs ACE (Customs Automated Commercial Environment) platform at the time of entry to enable CPSC to make admissibility decisions on the incoming merchandise based on that information. Goods that are classified under United States Harmonized Tariff Schedule numbers that are flagged for CPSC reporting will be affected by this change.
When eFiling product certificates, importers must provide seven data elements to complete a Certificate of Compliance, as specified in the Code of Federal Regulations, Title 16 – Commercial Practices, Part 1110 of the Consumer Product Safety Act Regulations https://www.ecfr.gov/current/title-16/part-1110 and https://www.ecfr.gov/current/title-16/section-1110.11 :
- Product ID: Identification of the finished product
- Citation Codes: Each consumer product safety rule to which the finished product has been certified
- Manufactured Date: Date when the finished product was manufactured
- Manufactured Location: Place where the finished product was manufactured, produced, or assembled, including the (1) name; (2) full address; and (3) contact information of the manufacturing party
- Product Test Date: Date when the finished product was most recently tested for compliance
- Test Lab: Party(ies) used for testing a certificate per 16 CFR Part 1110, including (1) name, (2) full address and (3) contact information of testing entity
- Point of Contact: Contact information for the party maintaining records of test results, including (1) name, (2) full address, and (3) contact information
Importers will be required to transmit Message Set data into CBP’s ACE system at the time of entry under either of the following methods:
- Full Message Set: The importer provides their broker with the full product certificate for the imported product and the broker files it in the CPSC PGA Message Set. This is recommended if the importer imports a limited number of regulated consumer products or does not repeatedly import the same product
- Reference PGA Message Set: The importer pre-enters the certificate data into the CPSC Product Registry (developed and maintained by CPSC) and then provides their broker with certificate identifiers to be filed in the PGA Message Set. The certificate identifiers are the Certifier ID, Product ID, and Version ID. This option is preferable if the importer repeatedly imports regulated consumer products covered by the same product certificates. By using the Product Registry, the importer can leverage manual or bulk upload features to file product certificate data in a streamlined and accelerated manner.
Visit CPSC’s eFiling site for training materials and other resources:
eFiling – CPSC Modern Approach for Filing Certificate Data: https://www.cpsc.gov/eFiling
eFiling Quick Start Guide – July 2024: https://www.cpsc.gov/s3fs-public/2024_07_08_eFiling_Quick_Start_Guide_FINAL_Draft.pdf
Electronic Filing of Certificate of Compliance Data: Announcement of Expansion of PGA Message Set Test and Request for Additional Participants: https://www.federalregister.gov/documents/2024/06/04/2024-12194/electronic-filing-of-certificate-of-compliance-data-announcement-of-expansion-of-pga-message-set
eFiling Quarterly Newsletters: https://www.cpsc.gov/eFiling/eFiling-Quarterly-Newsletters
Feel free to contact your Taggart/CTS Customs Brokerage team if you require further information. We will be available to assist you with the implementation of your CPSC eFiling program.
