Why Preparation Matters
The CPSC eFiling mandate (effective July 8, 2026) requires electronic filing of product certificates at the time of import. Unlike the current system where you keep certificates on file and produce them on request, the new system integrates certificate data into the customs entry process.
If your certificates are incomplete, outdated, or disorganized when the deadline hits, your shipments could be delayed at port. The time to get organized is now — not when your container is sitting at the dock.
Preparation Timeline
Phase 1: Audit (Do Now)
Review your existing certificates
Pull every CPC you currently have on file. For each one, verify:
- All 7 required elements are present and complete
- Product descriptions match your current SKUs and import documentation
- Testing lab CPSC acceptance is still current
- Test reports are recent enough to support current certification
- You (the U.S. importer) are listed as certifier, not your supplier
Phase 2: Fix (Now - 30 Days)
Address gaps in your documentation
- Create or update CPCs for any product missing a valid certificate
- Re-test products if test reports are outdated or labs have lost acceptance
- Correct certifier information if your factory is listed instead of your company
- Add missing elements (lab phone numbers are commonly absent)
- Ensure product descriptions are specific enough to match customs entries
Phase 3: Systemize (30 - 60 Days)
Set up your filing infrastructure
- Contact your customs broker to confirm they support CPSC eFiling through ACE
- Establish a process for providing certificate data with each customs entry
- Create a central repository for all CPC data in structured format
- Set up reminders to update certificates when products change or labs are re-tested
Phase 4: Test (60 - 80 Days)
Dry run before the deadline
- Submit a test entry with your broker to verify the eFiling process works
- Confirm your CPC data formats correctly in the ACE system
- Identify any products where you cannot produce compliant certificate data
- Resolve issues before July 8 when delays become costly
Document Checklist
For each children's product you import, you need:
Complete CPC with all 7 required elements
Supporting third-party test report(s) from CPSC-accepted lab(s)
Lab CPSC acceptance verification (check at cpsc.gov/labsearch)
Product photos matching the CPC product description
Tracking label images showing compliance with CPSIA Section 103
Customs entry data matching CPC product descriptions
Start with a properly formatted CPC for each product
Generate Your CPC NowCommon Preparation Pitfalls
- Waiting until after the deadline. Getting testing done, especially retesting, takes weeks. Labs have lead times. Start now.
- Relying on your supplier's certificate. If your supplier provides a CPC with their name as certifier, it is not valid for U.S. importation. You must issue your own.
- Assuming your broker will handle everything. Your customs broker files the entry, but the certificate data and its accuracy are your responsibility. They cannot create a CPC for you.
- Not checking lab acceptance. Labs can lose CPSC acceptance. A test report from a previously-accepted lab that has since been de-listed may not satisfy the filing requirement.
- Having one CPC for many products. While a CPC can cover a product line, each product must be identifiable from the certificate. Vague multi-product CPCs often fail scrutiny.
Starting from scratch? If you have been selling children's products without a CPC (which is already non-compliant), the eFiling mandate is the forcing function to get right. Better to fix it now voluntarily than to have a shipment refused at port.