CPSC eFiling Explained: What Toy Importers Must File Now and the January 2027 FTZ Deadline

Since July 8, 2026, importers of toys and other CPSC-regulated products must send certificate of compliance data electronically to U.S. Customs when they file entry. Products withdrawn from a foreign-trade zone (FTZ) follow on January 8, 2027, and no shipment is too small to be exempt.

What changed and when

The Consumer Product Safety Commission published its final rule revising 16 CFR part 1110 on January 8, 2025 (Federal Register, 90 FR 1800). It set July 8, 2026 for most imports and January 8, 2027 for goods entered from an FTZ for consumption or warehousing. CPSC confirmed the program took effect on July 8, 2026 (CPSC news release).

The rule changes how certificate data reaches CPSC, not what testing you do. CPSC states that eFiling "does not create new testing or certification requirements for importers" (Federal Register). For international mail, CPSC's September 1, 2026 bulletin said eFiled certificates would be required beginning October 22, 2026, using CBP's new Entry Type 13 (CPSC eFiling bulletin). CBP later extended the mandatory Entry Type 13 compliance date for covered international mail informal entries to January 20, 2027 (CBP Oct. 14, 2026 release).

CPSC webinar: eFiling Is 6 Months Away (official).

Who must file

Importers. The rule defines the importer as the importer of record. A customs broker can transmit the data, but the certifier "remains legally responsible" for its accuracy and completeness (16 CFR 1110.3 and 1110.15).

Toy manufacturers. If you manufacture overseas and bring goods into the U.S., whoever acts as importer of record files. Toy manufacturers producing in the United States do not eFile (CPSC news release), but they must follow the updated certificate content rules (CPSC certificates guidance).

Crowdfunded game publishers. If you ship a container to a U.S. warehouse, the importer of record files. If backers receive parcels directly from overseas, those are still commercial sales, and there is no de minimis exemption (CPSC eFiling FAQ). CPSC will not typically treat a consumer receiving a product for personal use as the importer (16 CFR 1110.3). First, check whether your game needs a certificate at all. Traditional board games and games with general-audience appeal are not children's products, but a junior version likely is (CPSC Children's Products FAQ). If no certificate is required, there is nothing to eFile. You can still file an optional "Disclaim" message, which CPSC says may improve your risk score (CPSC eFiling FAQ).

What data is filed

Each eFiled certificate carries seven data elements (CPSC eFiling FAQ):

• Product ID: a GTIN, SKU, UPC, model number, serial number, registered number or alternate ID
• Citation codes for each rule the product is certified to
• Manufacture date (at least month and year)
• Manufacture place, including the factory's name, address and contact details
• Most recent test date
• Testing laboratory, listing every lab whose results you rely on, including component-part tests
• Point of contact for test records

The certifier's attestation is built into the system (16 CFR 1110.11). Since July 8, 2026, you must also list any testing exclusion you rely on (CPSC eFiling FAQ).

There are two ways to file. With a Full PGA Message Set, you give your broker all seven elements for each entry. With a Reference PGA Message Set, you store certificates in CPSC's Product Registry and give your broker three identifiers: Certifier ID, Product ID and Version ID (CPSC eFiling FAQ). CPSC recommends the full method for companies importing a limited number of products and the reference method for repeat imports of the same products (CPSC Quick Start Guide).

Step-by-step checklist

1. List every product you import and confirm which CPSC rules apply, using CPSC's Regulatory Robot or the Small Business Ombudsman at [email protected] (CPSC eFiling FAQ).
2. Collect a current Children's Product Certificate or General Certificate of Conformity for each item. Each certificate may describe only one product (16 CFR 1110.13).
3. Check that each certificate has all seven elements, plus component-lab details and any testing exclusions.
4. Choose the full or reference method with your broker.
5. If you choose the reference method, open a Product Registry business account and enter certificates manually, by CSV upload or by API (CPSC eFiling FAQ).
6. Send your broker the data or the three identifiers before every entry.
7. Put at least one product ID on the packaging, packing list or invoice, as CPSC strongly recommends (CPSC eFiling FAQ).
8. If you use an FTZ, prepare now. Choose between a type 06 entry or weekly entry, check whether your inventory method (such as first-in, first-out) can supply the data, or consider a bonded warehouse with a type 21 entry (CPSC FTZ guidance).
9. Keep certificates and test records for five years, and be ready to produce a certificate within 24 hours of a CPSC or CBP request (16 CFR 1110.13 and 1110.17).
10. Send questions to [email protected].

Common mistakes

• Assuming low-value or direct-to-consumer parcels are exempt. They are not.
• Assuming your broker carries the legal risk. The certifier does.
• Assuming the Product Registry sends data to Customs. It does not communicate with CBP's ACE system, so your broker still needs your identifiers (CPSC eFiling FAQ).
• Leaving out labs that tested component parts.
• Reading "Customs won't reject the entry" as "eFiling is optional." CBP's notice to the trade states that eFiling is mandatory. It also says CPSC may reject the CPSC data and take enforcement action (CBP CSMS #69382435).
• FTZ users waiting until January.

What happens if you don't comply

For now, CPSC sends warnings rather than having entries rejected for missing data (CPSC eFiling FAQ). However, a missing or false certificate raises a shipment's risk score, which makes an exam more likely. CPSC can also refuse admission or ask CBP to seize goods (Federal Register).

Failing to furnish a required certificate is a prohibited act under federal law (15 U.S.C. 2068). Knowing violations carry civil penalties (15 U.S.C. 2069). The current maximum is $120,000 per violation and $17,150,000 for a related series (CPSC FY 2025 Agency Financial Report). The certificate attestation also warns that knowingly false statements are a federal crime (16 CFR 1110.11).

FAQ

Does eFiling apply to de minimis or low-value shipments?
Yes. "There is no Section 321 (also known as de minimis) shipment exemption for eFiling" (CPSC eFiling FAQ).

Do I have to use the CPSC Product Registry?
No. You only need it for the reference method. Brokers can file the full message set without it (CPSC eFiling FAQ).

When does eFiling apply to foreign-trade zones?
January 8, 2027. It applies to merchandise withdrawn from an FTZ for consumption or warehousing (CPSC FTZ guidance).

Do I need to eFile samples I bring in for trade shows or testing?
Samples that will never reach consumers do not need to meet CPSC requirements. CPSC advises using CBP's sample entry options, and for prototypes it points to HTS code 9817.85.01 (CPSC eFiling FAQ).

Does eFiling apply if I manufacture in the United States?
No. Domestic manufacturers do not eFile, but they must still issue compliant certificates (CPSC certificates guidance).

Sources

1. Federal Register, Certificates of Compliance final rule, 90 FR 1800
2. eCFR, 16 CFR part 1110
3. CPSC news release, July 8, 2026
4. CPSC eFiling FAQ
5. CPSC eFiling Guidance for Foreign Trade Zones (July 2025)
6. CPSC eFiling Quick Start Guide
7. CPSC, Update: Certificates of Compliance and eFiling
8. CPSC Children's Products FAQ
9. CPSC eFiling bulletin on mail shipments (Sept. 1, 2026)
10. CBP: Entry Type 13 mandatory date extended to Jan. 20, 2027
11. CBP CSMS #69382435 (July 29, 2026)
12. 15 U.S.C. 2068, prohibited acts
13. 15 U.S.C. 2069, civil penalties
14. CPSC FY 2025 Agency Financial Report (penalty maximums)

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