As of July 8, 2026, CPSC eFiling is mandatory for all U.S. importers of products covered by mandatory CPSC safety standards: seven Certificate of Compliance data elements must be transmitted to CBP at the time of entry through a PGA Message Set in ACE. ACE flags roughly 600 HTS codes under the rule, covering toys, children’s products, furniture, electronics, and household goods. Previously, importers kept the certificate on file and produced it only when CBP requested it during an examination. After July 8, that data goes into every covered entry proactively. For freight forwarders handling ocean import jobs in those categories, your team needs seven pieces of information from the importer before the entry is due. Importers filing through a Foreign Trade Zone have until January 8, 2027.
Not legal or compliance advice. This post covers the workflow implications of the CPSC eFiling mandate. Importers and their customs brokers should confirm specific filing requirements with licensed customs counsel.
What changed on July 8?
The rule changes when and how certificate data is filed rather than the underlying safety standard, which has been in force under CPSA Section 14 all along. The products that needed testing before July 8 still need it; what moved is the moment the paperwork meets CBP.
Today, importers maintain a Certificate of Compliance under CPSA Section 14. CBP can request it during an examination. The importer produces it from their records. Since July 8, that same data must go into the entry via the CPSC PGA Message Set in ACE, whether or not CBP asks. Two filing paths exist: the Full PGA Message Set transmits all seven data elements with each shipment, and the Reference PGA Message Set lets importers pre-register certificate data in the CPSC Product Registry and reference a stored identifier at entry. For importers shipping the same SKU repeatedly, the reference path cuts the per-entry work.
The legal obligation belongs to the importer of record. The forwarder just needs the data before the entry goes in, the same way ISF elements have to reach the filer before the 24-hour deadline.
What does enforcement look like in the first months?
A PGA mandate of this size rarely starts with maximum enforcement on day 1; the early weeks of any such rollout tend to be about rejected entry lines and requests for information rather than penalties. Whatever posture CPSC actually runs, that pattern is no reason to relax, for 2 reasons. First, a rejected entry line still stops your cargo: the release does not happen until the message set goes through cleanly, so the practical cost of missing data is measured in days at the port even when no penalty attaches. Second, the record being built now is the record enforcement will read later. An importer whose entries show a pattern of missing or corrected CPSC data through the autumn is the importer whose examinations get slower next year.
For the forwarder, the working assumption should be that every covered entry either carries clean data or costs a delay. That assumption was true on July 9 and it will be more true each month.
Which shipments are affected?
ACE has flagged roughly 600 HTS codes since July 8, but the flag is a workflow alert, not the compliance test. Your obligation depends on the product: if it is subject to a mandatory CPSC safety standard, you must file the certificate data, flagged HTS code or not.
Categories that commonly require CPSC certificates include children’s toys under ASTM F963, infant and toddler products under 16 CFR Part 1237 and related rules, cribs and sleep surfaces, children’s furniture, battery-powered consumer electronics, and certain household goods. If your jobs regularly include these commodity types, the mandate already applies to part of your current workload.
Goods entering through a Foreign Trade Zone have until January 8, 2027.
The practical test for a forwarder triaging a book of business: sort your last 90 days of ocean import jobs by commodity description and pull everything that reads like a consumer product a child might touch, a piece of furniture, or a battery-powered device. That rough cut takes an hour and catches most covered freight. The edge cases, a commodity description that says only “household goods” or “general merchandise,” are exactly the ones to push back on now, because a vague description that was tolerable before is a description that cannot be screened against 600 flagged HTS codes.
What seven data elements does your team need?
All seven come from the Certificate of Compliance the importer already holds.
- Product identifier (SKU, model number, or other identifier tied to the certificate)
- Cited CPSC safety rule (the specific regulation the certificate covers)
- Date of manufacture
- Place of manufacture
- Date of most recent compliance testing
- Testing laboratory contact information
- Point of contact maintaining the certificate records
The certificate has all seven fields. The problem is getting them to your entry filing team before the cargo arrives.
What if the importer cannot produce the certificate?
This is the scenario worth planning for, because it will happen within the first 90 days of handling covered freight. An importer, often a smaller one buying through a trading company, answers the certificate request with a blank pause: the factory did the testing, the supplier has the paperwork, someone will find it.
The forwarder’s move is sequencing, and it has 3 steps. First, put the question at booking rather than arrival, so the pause happens while the cargo is still weeks out instead of sitting at the port. Second, be concrete about what missing data costs: the entry line will not clear, and every day of delay after free time is a demurrage day the importer pays for. Third, document the ask. If the entry is late because the importer could not produce a test date, the email trail showing the request went out at booking is what keeps the delay from becoming the forwarder’s fault in the customer’s mind.
None of this makes the forwarder responsible for compliance; that stays with the importer of record. It makes the forwarder the party that saw the problem 3 weeks before it became expensive, which is the version of this story that keeps the account. If your current workflow still asks for this data at the arrival stage, every covered entry is now a race against the vessel.
What freight forwarders should have in place now
The mandate is live, so this is a running checklist rather than a countdown. Waiting until the cargo is at port was never the plan.
Identify which open jobs are in affected categories. Pull your active ocean import jobs and flag anything in toys, children’s products, consumer electronics, furniture, or household goods. Get the list before making any calls.
Contact those importers now. Tell them the mandate is in force and ask them to confirm their Certificate of Compliance is current with all seven fields. Send the list above so the ask is specific.
Confirm your customs broker’s ACE setup. If a licensed customs broker handles your ACE filings, verify they are transmitting CPSC PGA Message Sets cleanly. Your broker needs the same seven data elements, and your team reviews every entry before it goes in.
Move the data request upstream. For any of these product types going forward, build CPSC certificate collection into the pre-alert or booking stage. The port is the wrong place to discover a test date is missing.
Decide where the seven fields live on the job. A certificate PDF buried in an email thread does not count as having the data. The seven elements belong on the job record, next to the ISF data, where the entry filer can pull them without an inbox search. If your team cannot answer “where is the test date for this SKU” in under a minute, the data is not really collected.
Use the Product Registry for repeat SKUs. An importer shipping the same 20 SKUs all year should pre-register once and reference the stored certificate identifier on every entry, rather than transmitting all 7 elements fresh each time. The reference path exists precisely for that repeat pattern, and it turns a per-shipment data chase into a once-a-year certificate refresh.
The importer of record carries the legal exposure. The freight forwarder carries the workflow. Those seven data elements need to move through your inbox-to-TMS process ahead of the entry, and never show up for the first time the day the cargo arrives.
The inbox-to-TMS gap is where this kind of mandate bites: the certificate data sits somewhere in your email thread or document attachments, but your team never has it on the right job record when the entry is due. TIO reads inbound emails and documents across your open jobs, binds each one to the right shipment record, and surfaces what your ops team needs to confirm the entry is complete before the deadline. Your team reviews and approves every TMS write. If you want to see how that works with your setup, book a demo.
Frequently asked questions
What is CPSC eFiling and when does it take effect?
CPSC eFiling requires importers of products subject to mandatory CPSC safety standards to transmit seven Certificate of Compliance data elements to CBP electronically at the time of entry. It took effect July 8, 2026. Previously, importers kept the certificate on file and produced it only if CBP requested it during an examination. Now that certificate data must be filed proactively with every covered entry through a CPSC PGA Message Set in ACE. Importers filing goods through a Foreign Trade Zone have until January 8, 2027.
Which shipments are affected by CPSC eFiling?
The compliance obligation flows from whether the product itself is subject to a mandatory CPSC safety standard. Roughly 600 HTS codes are automatically flagged in ACE as of July 8, 2026, covering toys, children's products, furniture, electronics, and similar consumer goods categories. A shipment can be affected even if its specific HTS code is not flagged, if the product meets the coverage criteria for a mandatory CPSC rule. The importer of record is legally responsible for confirming whether their product requires eFiling.
What seven data elements are required for CPSC eFiling?
The 7 required data elements are: product identifier, the cited CPSC safety rule, date of manufacture, place of manufacture, date of most recent compliance testing, testing laboratory contact information, and the point of contact maintaining the certificate records. All 7 must be transmitted via a CPSC PGA Message Set in ACE at the time of entry, either filed fresh per shipment or referenced from a pre-registered certificate in the CPSC Product Registry.
What should freight forwarders tell importers now that eFiling is live?
Freight forwarders should confirm with every importer of CPSC-regulated consumer products that the Certificate of Compliance is current and contains all 7 required data elements. The legal obligation belongs to the importer of record, but the forwarder needs that data before the entry is filed. For affected shipments, ask at booking, before the cargo is at port and the entry deadline is hours away.