If you import toys, children’s products, household goods, apparel, or other regulated consumer products into the United States, the way you handle CPSC compliance has changed.

As of July 8, 2026, the U.S. Consumer Product Safety Commission’s mandatory eFiling program is in effect for importers of most regulated consumer products that require certificates of compliance.

Instead of simply maintaining a certificate and producing it when requested, importers subject to the requirement must now electronically submit certificate information through U.S. Customs and Border Protection’s import system.

For many established importers, this is primarily a change in how compliance information is transmitted.

For smaller importers, resellers and businesses buying branded products through overseas distributors, however, eFiling can expose a much bigger problem:

You may not actually have all the information required to certify the product.

You may know the brand.

You may have a SKU or UPC.

The package may say “Made in China.”

But do you know the actual manufacturer, production location, applicable CPSC rules, testing information and party maintaining the compliance records?

This guide explains how the pieces fit together.

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Quick Answer: What Is CPSC eFiling?

CPSC eFiling is the electronic submission of product certificate information for regulated imported consumer products.

The program became mandatory for most regulated imports requiring certification on July 8, 2026. CPSC says the system is intended to give the agency certificate information before products enter U.S. commerce, allowing it to identify higher-risk shipments more efficiently while reducing unnecessary inspections of compliant imports.

A useful way to understand the process is:

Product → Applicable Rules → Testing → CPC/GCC → Certificate Data → eFiling → Import

eFiling does not mean that every product imported into the United States suddenly requires laboratory testing.

The first question is still:

Does your product require CPSC certification at all?

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1. Does Your Product Require CPSC Certification?

Do not send a product to a laboratory simply because it is being imported into the United States.

First determine which CPSC rules, bans, standards or regulations apply to the product and whether they require certification.

CPSC maintains separate resources covering rules that require certification for children’s products and rules requiring a General Certificate of Conformity for general-use products.

This distinction matters because testing requirements can be very different.

For example, children’s products subject to applicable children’s product safety rules generally require testing by a third-party CPSC-accepted laboratory.

General-use products subject to certification requirements generally require a General Certificate of Conformity (GCC) based on testing or a reasonable testing program, but they do not necessarily require testing by a CPSC-accepted third-party laboratory.

So before ordering testing, identify:

• What exactly is the product?
• Who is it designed or intended for?
• What CPSC rules apply?
• Is certification required?
• What type of testing supports that certification?

This step can prevent unnecessary testing — or worse, paying for the wrong tests.

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2. CPC vs. GCC: What’s the Difference?

Two terms appear constantly in CPSC compliance:

CPC — Children’s Product Certificate

A Children’s Product Certificate applies to children’s products subject to applicable children’s product safety requirements.

For imported children’s products, the importer is generally responsible for issuing the CPC based on passing third-party testing from a CPSC-accepted laboratory.

A common misunderstanding is that the laboratory “issues the CPC.”

It doesn’t.

The laboratory performs the testing and provides the test results. The responsible manufacturer or importer issues the certificate based on those results.

GCC — General Certificate of Conformity

A GCC applies to certain general-use, non-children’s products subject to CPSC rules requiring certification.

For products manufactured overseas, the importer is generally responsible for issuing the GCC based on testing or a reasonable testing program. Unlike children’s products, a CPSC-accepted third-party laboratory is not automatically required.

In simplified terms:

Product	Typical Certificate	Testing
Regulated children’s product	CPC	Generally CPSC-accepted third-party lab
Regulated general-use product	GCC	Testing or reasonable testing program, depending on applicable rule

The exact requirements depend on the product and applicable regulations.

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3. How to Send a Product for CPSC Testing

If your children’s product requires third-party testing, don’t simply choose a general testing company.

CPSC accepts laboratories for specific testing scopes, and CPSC maintains an official searchable database of accepted laboratories.

Find a CPSC-Accepted Laboratory

A practical testing process usually looks like this.

Step 1 — Identify the applicable requirements

Determine which CPSC rules apply to the product.

Depending on the product, this could involve requirements relating to areas such as lead, phthalates, small parts, toy safety or other product-specific standards.

Do not assume every product requires the same testing package.

Step 2 — Find a laboratory with the correct scope

Check that the laboratory is CPSC-accepted for the particular tests you need, not simply that the company operates a testing laboratory.

CPSC notes that laboratories are accepted to assess compliance with particular children’s product safety rules.

Step 3 — Send the lab your product information

Useful information can include:

• Product name
• Model number
• SKU / UPC / GTIN
• Product photographs
• Packaging photographs
• Intended age group
• Materials
• Manufacturer information
• Product specifications
• Existing test reports
• Applicable CPSC requirements, if already identified

Ask the laboratory to confirm the proposed testing scope before sending samples.

Step 4 — Get a quotation and sample requirement

The laboratory should tell you:

• Tests proposed
• Number of samples required
• Testing cost
• Estimated turnaround time
• Documents required

Step 5 — Send representative samples

Make sure the samples correspond to the product you intend to certify and import.

Step 6 — Complete testing

The laboratory conducts the agreed testing.

Step 7 — Receive and review the test report

Check that the report correctly identifies your product and covers the applicable requirements.

And remember:

A passing laboratory report is not the same thing as a CPC.

CPSC specifically warns online sellers that submitting a laboratory report does not itself satisfy CPC requirements.

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4. What Information Does CPSC eFiling Require?

This is where the new system becomes particularly important.

For a Full PGA Message Set, CPSC identifies seven required certificate data elements:

Data Element	What You Need
1. Product ID	Identification of the finished product
2. Citation Codes	Applicable CPSC rules to which the product is certified
3. Manufacture Date	When the finished product was manufactured
4. Manufacture Place	Where and by whom it was manufactured, produced or assembled
5. Product Test Date	When the finished product was most recently tested
6. Testing Laboratory	Relevant testing party information
7. Point of Contact	Party maintaining the test records

One field is particularly difficult for importers who buy through overseas intermediaries:

Manufacture Place

CPSC’s eFiling guidance describes this as the place where the finished product was manufactured, produced or assembled, including the manufacturing party’s:

• Name
• Full address
• Contact information

That means:

“Made in China” is not the same thing as knowing the actual manufacturing party.

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5. The Hidden Problem: You May Not Know Who Actually Manufactured Your Product

This can happen surprisingly often.

Imagine that you are a U.S. importer buying branded products from a distributor in Japan.

The package identifies the Japanese brand.

The product says:

Made in China

But the distributor doesn’t tell you which Chinese factory actually manufactured or finally assembled the product.

Searching the brand name online may lead you to:

• A corporate office
• A Chinese subsidiary
• A quality-control office
• A distributor
• A trading company
• A sourcing company

None of these necessarily proves that the entity was the actual manufacturer of the product.

For eFiling and certification purposes, guessing is a bad strategy.

If the information is unavailable from your supplier, it may require deeper supply-chain research, product-code tracing and direct communication with potential manufacturing parties.

This is one of the areas where having someone on the ground in China can become useful.

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6. What Should Be on a CPC?

For a Children’s Product Certificate, CPSC requires information covering the product, applicable safety rules, certifying party, records contact, manufacture information, testing information and laboratory information.

A practical checklist includes:

Product identification

Enough detail to identify the exact product covered by the certificate.

Applicable safety regulations

The certificate must identify the applicable children’s product safety rules.

Importer or domestic manufacturer

For an imported product, identify the responsible importer as required.

Records contact

Identify the person maintaining the supporting test records.

Date and place of manufacture

CPSC’s CPC guidance says the manufacture date should include at least month and year.

For the manufacturing location, provide at least the city or administrative region, state where applicable, and country. If the same manufacturer has multiple locations within the same city, the factory street address should be provided.

Date and place of testing

Identify when and where the product was tested.

CPSC-accepted laboratory

Identify the relevant third-party laboratory on whose testing the CPC depends.

A CPC does not require a special government-issued form. CPSC provides a sample, but businesses may use their own format as long as the required information is included.

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7. How Does the CPSC Product Registry Work?

CPSC now operates the Product Registry, a secure online system where importers can store and manage product certificate data.

Self-registration is currently open.

CPSC Product Registry

There are two important ways certificate information can be transmitted during importation.

Option 1 — Full PGA Message Set

The importer provides the broker with all seven required product certificate data elements.

The broker transmits them through the CPSC PGA Message Set in CBP’s Automated Commercial Environment (ACE).

Conceptually:

Importer → Certificate Data → Broker → ACE → CPSC

Option 2 — Reference PGA Message Set

Instead of transmitting all seven elements every time, the importer can first enter and certify the product certificate data in the CPSC Product Registry.

The importer then provides the broker with three Certificate Identifiers:

• Certifier ID
• Product ID
• Version ID

The broker uses those identifiers in the Reference PGA Message Set.

Conceptually:

Importer → Product Registry → Certificate Identifiers → Broker → ACE

One important detail:

The Product Registry does not automatically communicate with CBP’s ACE system.

The importer still needs to provide the relevant identifiers to the broker for filing.

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8. Repeatedly Importing the Same Product? The Product Registry Matters

This is particularly useful for businesses importing the same SKUs repeatedly.

CPSC says Reference PGA Message Sets are preferable where regulated products covered by the same certificate are imported repeatedly.

As long as the certificate details remain identical, the certificate can remain in the Product Registry and be referenced for multiple shipments.

For example, an importer regularly bringing the same collectible, toy or consumer product into the U.S. may be able to maintain the product certificate data once and reference it on subsequent imports rather than rebuilding all seven data elements for every shipment.

That makes accurate product identifiers particularly important.

CPSC recommends using at least one identifier that appears on product packaging, packing lists or invoices where possible.

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9. Does CPSC eFiling Apply to Low-Value or Small Shipments?

Do not assume a shipment is exempt simply because it is small.

CPSC’s current guidance specifically addresses direct-to-consumer, mail and de minimis imports and identifies who may be considered the importer responsible for certification in those circumstances.

Commercial transactions can still fall within eFiling requirements even when products move between individual buyers and sellers.

CPSC’s FAQ distinguishes genuinely noncommercial transactions — such as certain gifts or transfers of personal effects — from transactions involving a sale. Sales through online marketplaces remain commercial transactions for this purpose.

So:

Small shipment ≠ automatically exempt.

And:

Online marketplace purchase ≠ automatically noncommercial.

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10. What About EMS and International Mail Shipments?

This has become especially important for small importers buying products from Japan, China and other overseas markets.

CPSC has published specific guidance for mail shipments and introduced Entry Type 13 for complying with eFiling requirements in that context.

CPSC eFiling Document Library

That means businesses regularly importing commercial merchandise using international postal channels such as EMS should not simply assume the eFiling requirement applies only to conventional freight or large customs entries.

The exact filing process depends on the shipment and entry arrangement.

If you regularly import regulated products through EMS or another international mail service, determine:

• Who is acting as the importer for CPSC certification purposes?
• Who handles the U.S. customs entry?
• Does the product require a certificate?
• Who will transmit the required eFiling data?
• Will you use a Full PGA or Reference PGA approach where applicable?
• Do you have all required manufacturer and testing information before shipment?

For shipment-specific customs procedures, importers should work with an appropriately qualified customs broker or other authorized filing party.

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11. Common CPSC eFiling Mistakes

Several mistakes can create unnecessary problems.

Mistake 1: Assuming “Made in China” identifies the manufacturer

It doesn’t.

You may still need the actual manufacturing party and location.

Mistake 2: Using the brand owner’s address as the factory address

The brand owner, distributor, Chinese subsidiary and actual manufacturer can be different entities.

Verify rather than assume.

Mistake 3: Sending samples to a lab before identifying applicable rules

You may pay for tests you don’t need — or miss tests that you do.

Mistake 4: Assuming any testing laboratory is acceptable for children’s products

For applicable children’s product third-party testing, confirm that the laboratory is CPSC-accepted for the relevant scope.

Mistake 5: Treating the laboratory report as the CPC

The test report supports certification.

It does not replace the CPC.

Mistake 6: Assuming the laboratory is legally responsible for issuing your CPC

For imported children’s products, the importer generally remains responsible for issuing the CPC, even when a laboratory or consultant helps prepare it.

Mistake 7: Waiting until the shipment is already at U.S. Customs

The new eFiling system is designed to provide certificate information before regulated products enter U.S. commerce.

Prepare the supply-chain and testing data earlier.

Mistake 8: Assuming low-value commercial shipments are automatically exempt

Shipment value alone does not answer the certification/eFiling question.

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12. A Practical CPSC Import Workflow

For an imported regulated product, the overall process can look like this:

1. Identify the exact product

SKU, UPC, model, photographs, intended use and age grading.

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2. Determine applicable CPSC requirements

Identify the relevant rules and certification requirements.

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3. Identify the actual manufacturer

Confirm the manufacturing party and production location rather than relying solely on brand or distributor information.

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4. Arrange appropriate testing

For applicable children’s products, use a CPSC-accepted laboratory with the necessary scope.

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5. Obtain the test report

Review product identification and applicable test results.

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6. Prepare the CPC or GCC

The responsible certifying party creates the applicable certificate based on appropriate supporting testing.

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7. Organize the seven eFiling data elements

Product ID, citations, manufacture information, testing information and records contact.

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8. Decide how the certificate will be filed

Full PGA Message Set or Product Registry + Reference PGA Message Set.

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9. Coordinate with the customs filing party

Make sure the required data or certificate identifiers are available for entry.

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10. Keep the information updated

If the product, manufacturing details, applicable rules, testing or certificate information changes, determine whether the certificate data needs to be updated.

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Need Help With the China Side of CPSC Compliance?

One of the hardest parts of CPSC compliance can occur before the filing itself.

You may have the product.

You may know the brand.

You may even have a laboratory ready to test it.

But critical information from the China side may still be missing.

ChinaDone can help with practical China-side work such as:

Manufacturer Identification
Research the actual Chinese manufacturer or final assembler behind a product.

Manufacturer Verification
Verify Chinese company information, addresses and available contact details.

Factory Communication
Contact potential manufacturers in Chinese to confirm product and production information.

Product & Supply-Chain Research
Trace SKUs, UPCs, product codes, packaging information and other available evidence.

Testing Coordination in China
Help identify appropriate testing resources, coordinate quotations, samples and communication.

Document & Information Collection
Coordinate with Chinese manufacturers or suppliers to collect available production and compliance information.

China-Side Compliance Coordination
Organize information for your importer, testing laboratory, compliance consultant or customs broker.

Missing information for your CPSC filing?

Send us whatever you already have — product photos, packaging, SKU, UPC, supplier information, test reports or existing documents.

We’ll tell you what can reasonably be investigated or coordinated in China.

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Important: ChinaDone provides China-side research, communication and coordination support. We are not a U.S. customs broker, CPSC-accredited testing laboratory, or law firm, and we do not determine legal compliance or guarantee CPSC acceptance. Importers and other responsible parties should confirm product-specific requirements with CPSC, their testing laboratory, compliance professional and/or customs broker as appropriate.

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FAQ

When did CPSC eFiling become mandatory?

CPSC’s mandatory eFiling program went into effect on July 8, 2026 for importers of most regulated consumer products requiring certificates of compliance.

Does every product imported into the U.S. require CPSC testing?

No. Testing and certification requirements depend on the product and the CPSC rules, bans, standards or regulations applicable to it.

Do children’s products need a CPSC-accepted laboratory?

Children’s products subject to applicable children’s product safety rules generally require third-party testing by a CPSC-accepted laboratory to support certification.

Does the testing laboratory issue the CPC?

No. The laboratory performs testing and provides results. For an imported children’s product, the importer is generally responsible for issuing the CPC based on appropriate passing third-party test results.

Is “Made in China” enough for CPSC eFiling?

Not necessarily. The eFiling manufacture-location data includes information about the party that manufactured, produced or assembled the finished product, including its name, full address and contact information.

Can I store certificate information for products I import repeatedly?

Yes. The CPSC Product Registry allows importers to store certificate data and use Certificate Identifiers in Reference PGA Message Sets. CPSC specifically notes this can be useful for repeatedly imported products covered by identical certificate information.

Does CPSC eFiling apply to EMS or international mail?

CPSC has issued specific eFiling guidance for mail shipments using the new Entry Type 13. The exact requirements depend on the product and import arrangement, so commercial importers using postal channels should evaluate their particular shipments rather than assuming mail is exempt.