CPSC eFiling for EMS & International Mail: What U.S. Importers Need to Know in 2026
If you regularly receive commercial products from overseas through EMS or international postal mail, an important change is coming on October 22, 2026.
U.S. Customs and Border Protection (CBP) is introducing Entry Type 13, a new electronic entry process for international mail shipments. For products subject to U.S. Consumer Product Safety Commission (CPSC) certification requirements, the required certificate data will also need to be electronically filed.
For small importers who have traditionally relied on their overseas supplier to attach customs documents to the package, this can create a new challenge.
Here is what you need to know.
How EMS Shipments Traditionally Work
A typical commercial EMS shipment may look like this:
Overseas Supplier → EMS / Postal Service → U.S. Customs → USPS → Importer
The overseas supplier normally prepares documents such as:
EMS shipping documents
CN23 customs declaration
Commercial invoice
Product description and value
Country of origin
These documents may physically accompany the shipment.
For example, a commercial EMS shipment can include a CN23 customs declaration containing the product description, quantity, value and country of origin, together with a separate commercial invoice.
However, physical customs paperwork alone may no longer be sufficient for certain products.
What Changes on October 22, 2026?
CBP is introducing Entry Type 13 for qualifying international mail shipments.
At the same time, CPSC has confirmed that beginning October 22, products arriving through international mail that are subject to CPSC certification requirements will need the relevant certificate information electronically filed through the new process.
In simple terms:
Before: Your supplier may have been able to attach the necessary paperwork to the EMS package.
Now: Certain information may also need to reach U.S. authorities electronically.
Does Every EMS Shipment Require CPSC eFiling?
No.
CPSC eFiling applies to products that are subject to CPSC certification requirements.
This can include many regulated consumer products, particularly categories such as children’s products and toys.
A collectible figure marketed to adults, for example, may have different requirements from a children’s toy.
Therefore, one of the first questions an importer should determine is:
Is my product subject to a CPSC rule that requires certification?
If it is, additional product and compliance information may need to be prepared.
What Information May Be Needed?
Depending on the product and applicable requirements, eFiling can involve information such as:
Product identification
Manufacturer information
Manufacturing location
Manufacturing date
Applicable CPSC rules
Testing information
Testing laboratory
Certificate information
Importer information
CPSC’s Product Registry allows certificate information to be created and maintained electronically.
This is why some overseas suppliers and importers may suddenly find themselves being asked for information they did not routinely provide before — such as the actual manufacturer’s address.
Do I Need a Customs Broker?
Not necessarily.
An eligible importer can potentially make its own customs filings, but doing so requires understanding and accessing CBP’s electronic filing infrastructure.
For many small and medium-sized importers, working with a licensed U.S. customs broker is considerably easier.
A practical workflow may therefore look like:
Overseas Supplier ↓ Provides product, manufacturer and shipment information
U.S. Importer / Compliance Coordinator ↓ Organizes CPSC certificate and product data
Licensed U.S. Customs Broker ↓ Submits the required customs/PGA data electronically
CBP / CPSC ↓ Processes the entry
USPS ↓ Final delivery
What If I Import Regularly From Japan, China or Other Countries?
The country you purchase from is not necessarily the main issue.
What matters is:
what the product is, how it enters the United States, who the importer is, and which U.S. regulations apply to it.
So an importer receiving EMS shipments from Japan may face the same basic question as one receiving international postal shipments from another country:
Who will prepare and electronically submit the required U.S. import and compliance information?
If your existing overseas supplier only handles the physical EMS shipment, you may need additional support on the U.S. compliance and filing side.
ChinaDone Can Help Coordinate the Process
If you’re unsure how the new requirements affect your existing EMS shipments, you don’t necessarily need to figure everything out yourself.
ChinaDone can help with:
Reviewing your existing shipment process
Identifying the information you may need
Coordinating with your overseas supplier or manufacturer
Organizing manufacturer and product information
Assisting with CPSC Product Registry preparation
Coordinating with a licensed U.S. customs broker for customs filing
Helping manage the process for recurring shipments
ChinaDone is not a U.S. licensed customs broker. Customs brokerage services, where required, are performed through appropriately licensed service providers.
Already importing through EMS?
If you’re currently receiving commercial shipments from Japan, China or elsewhere and aren’t sure what needs to change before October 22, send us your current shipping setup.
Tell us what you’re importing and how it’s currently shipped. We’ll help you work out the next step.
Not Sure How to Handle eFiling?
Let Us Help You Navigate It.
Tell us what you’re importing and how it’s currently shipped. We can help organize the required information and coordinate the filing process with a licensed U.S. customs broker.
CPSC eFiling 2026: A Practical Guide for U.S. Importers
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.
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.
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?
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
↓
2. Determine applicable CPSC requirements
Identify the relevant rules and certification requirements.
↓
3. Identify the actual manufacturer
Confirm the manufacturing party and production location rather than relying solely on brand or distributor information.
↓
4. Arrange appropriate testing
For applicable children’s products, use a CPSC-accepted laboratory with the necessary scope.
↓
5. Obtain the test report
Review product identification and applicable test results.
↓
6. Prepare the CPC or GCC
The responsible certifying party creates the applicable certificate based on appropriate supporting testing.
↓
7. Organize the seven eFiling data elements
Product ID, citations, manufacture information, testing information and records contact.
↓
8. Decide how the certificate will be filed
Full PGA Message Set or Product Registry + Reference PGA Message Set.
↓
9. Coordinate with the customs filing party
Make sure the required data or certificate identifiers are available for entry.
↓
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.
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.
NEED HELP WITH THE CHINA SIDE?
Missing information for your CPSC filing?
Send us the product photos, SKU, UPC, supplier details, test reports, or other information you already have. We can help investigate the Chinese manufacturer, verify company details, contact factories, and coordinate China-side information for your compliance process.
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.
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.