Effective July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) is implementing a mandatory electronic filing (e‑Filing) requirement for Certificates of Compliance (Children’s Product Certificate (CPC) or General Certificate of Conformity (GCC)) for all regulated finished consumer products imported into the United States.
Importers must submit certificate data electronically in Customs Automated Commercial Environment (ACE) at time of entry using either the Full Partner Government Agency (PGA) Message Set (7 data elements from the certificate), the Reference Message Set (3 data elements) for products which have been registered on the CPSC Product Registry or the applicable exemption indicator and intended use code.
To obtain the Product Reference Message Set, the importer or manufacturer responsible for certifying the products with the CPSC should establish a business account on the CPSC Product Registry and then will need to electronically register each of their products by entering information from their respective certificates of compliance (either CPC or GCC).
What types of products and specific harmonized tariff codes (HTS) are subject to the new eFiling requirements?
The regulation covers finished consumer goods such as:
- Clothing
- Shoes
- Bicycles and bicycle helmets
- Children’s furniture, carriages, strollers, sleep products
- Toys
- Other finished consumer goods
The full list of impacted HTS codes can be found here.
What are the data elements specific to the Full PGA Message Set and Reference Message Set?
The 7 required certificate data elements for the Full CPSC PGA Message Set (which can be found on the CPC or GCC) are:
- Product ID (as identified by the certifier/importer)
- Citation data – reference to each applicable CPSC regulation (e.g., CPSIA sections, 16 CFR parts)
- Date of manufacture
- Place of manufacture (country, city/factory as applicable)
- Date of most recent test
- Testing laboratory information (CPSC-accepted lab, where applicable)
- Recordkeeper / point of contact information
The 3 data elements for the Reference Message Set (for customers who leverage the Product Registry) are:
- Product ID – A unique identifier for the product being certified
- Certifier ID – The unique identifier created by the certifying importer
- Version ID – The unique identifier for the specific version of the product certificate
Impact on Shippers Sending to the US
Shippers sending from Rest of World to USA must provide either: Full Certificate Data (7 elements) on the commercial invoice either in the line-item description field or in the remarks section on a standard DHL generated invoice template or A copy of the CPC/GCC or Product Registry Identifiers (Product ID, Certifier ID, Version ID) on the commercial invoice either in the line-item description field or in the remarks section or Disclaim code and applicable intended use code on the commercial invoice either in the line-item description field or in the remarks section.
Must understand which CPSC rules apply to each individual part number/SKU (CPC vs GCC).
Must ensure accuracy of testing, manufacturing, and applicable code of federal regulation citation data.
What can shippers do to avoid delays?
Provide certificate information, product registry identifiers, or disclaim code BEFORE the shipment arrives either by including the relevant information on the commercial invoice or by attaching the GCC or CPC certificates to the shipment documentation. If using the CPC or GCC, it is recommended to either providing a copy of the respective certificate with each shipment or alternatively, customers can provide an addendum sheet with the relevant GCC or CPC data elements. ▪ These documents can either be uploaded when shipping utilizing Paperless Trade or by tendering a copy of the documents along with the shipment commercial invoice and airway bill copy when the courier makes the pick-up
Ensure harmonized tariff codes (HTS) codes are correct and check against the CPSC flagged list to ensure proper certifications and information are available for clearance teams.
Ensure CPSC product testing and documentation are current and correct.
Impact on US Importers
The US Importer of Record (IOR) is legally responsible for certificate accuracy.
The US IOR must review their products against CPSC flagged HTS codes to understand which items will require the additional data elements to comply with July 8 go live of electronic CPSC filing For products subject to CPSC, it is recommended that the IOR set-up a CPSC Product Registry business account and register their products in the CPSC Product Registry. Information on this process can be found here: CPSC Product Registry | CPSC.gov
DHL Express USA will contact the Importer of Record for missing CPSC information should the required data elements not be on file, provided with shipment documentation, or on the commercial invoice. Missing data may lead to delays in receiving full release from both U.S. Customs and CPSC.
Must maintain valid CPC/GCC even when HTS code is not flagged
Must have Power of Attorney on file with DHL Express USA if importing shipments with values above $5,000 USD
What can receivers do to avoid delays?
Confirm whether imported SKUs fall under the flagged HTS codes.
- Provide DHL Express with Product Registry IDs or Full 7 Data Elements prior to shipment arrival in the US. This can be done via the following: Providing a product database to Preferred Shipping Customer Service so we can update your Customer Master File (CMF); or
- Ensure all information is on the commercial invoice; or
- Applicable certificates or addendums are sent to the shipper to provide to DHL Express at time of shipment creation as part of shipment documentation
- Maintain updated certificates when manufacturing batches change.
Additional Resources:
- CPSC eFiling Program
- CPSC Product Registry
- CPSC Regulatory Robot
- CPSC Flagged HTS Code List
- CPSC eFiling Guidance (FAQs & Program Info)
- CPSC Guidance and HTS List for Filing of Electronic Certificates
- DHL Express eFiling Overview
- DHL Express CPSC eFiling Regulatory Changes
