Are you prepared for the new USA CPSC eFiling Mandate?

What is it?

The U.S. Consumer Product Safety Commission (CPSC) now requires electronic filing (eFiling) of safety certificate data. Instead of just keeping a PDF on file, importers (or manufacturers on their behalf) must now submit digital proof that their products meet U.S. safety standards at the exact moment the goods enter the country.

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Who is the "Importer"?

For these rules, the Importer of Record (usually the U.S. company buying the goods) is the responsible party. They must create the CPSC Business Account. While a Customs Broker is often hired by the importer to handle the digital paperwork at the border, the legal burden of providing accurate safety data and maintaining the original test records falls on the importer.

Do manufacturers need to do anything?
Manufacturers cannot create their own independent "Global ID." Instead, you work as a Collaborator within your customers' (importers) accounts.

• You can use one email address to manage data across multiple importer accounts.
  
• To avoid manual entry, manufacturers should maintain a Master CSV file. You can upload this file into each importer's account to generate their specific Reference IDs instantly.
  
• Request that importers use the "Trade Party Privacy" setting so your data is only visible to that specific customer.
  

What products are impacted?
Any products that require a General Certificate of Conformity (GCC) or a Children’s Product Certificate (CPC) must be eFiled. This includes, but is not limited to:

• Apparel: Children's sleepwear and most "general wear" clothing.
• Children's Goods: Toys, strollers, high chairs, and juvenile furniture.
• Home & Safety: Mattresses, bicycle helmets, lighters, and paint/surface coatings.
• Furniture: Clothing storage units (due to tip-over standards).
• Products containing coin cell or button batteries

Low-Value Shipments: A major change is that low-value shipments (those valued under $800) are no longer exempt from safety paperwork. If your product is regulated, it must be eFiled, even if it is a single small package or a "de minimis" shipment that previously entered the country with no documentation.

Special Mention: Reese’s Law (Battery Products)If you sell products containing button cell or coin batteries, they are now subject to strict safety standards (16 CFR § 1263). Because these products require a GCC or CPC, they fall directly under this new eFiling mandate. Impacted battery products include:

• Electronics: Remote controls, key fobs, and digital watches.
• Household Items: Kitchen scales, thermometers, and lighted decorations.
• Children's Products: Any battery-operated toy (requires a CPC).
• Wearables: Fitness trackers and small medical devices.

What is the deadline?

July 8, 2026: Mandatory eFiling begins for all standard imports. After this date, shipments missing this digital data will likely be flagged, delayed, or seized at the port.

How should Manufacturers Prepare?

1. Identify Regulated Goods: Audit your inventory for anything containing button/coin batteries or subject to CoC/CPC requirements.
2. Use the Product Registry: Upload your certificate data to the CPSC Product Registry in advance. This creates a "Master File" for your products (https://www.cpsc.gov/eFiling-CPSC-Product-Registry)
3. Provide the Reference ID: Include this ID number clearly on your Commercial Invoice and Packing List. This allows the importer’s Customs Broker to clear your goods instantly without needing to manually re-type your test data into the U.S. system.
4. Talk to Your Freight Forwarder: Ensure they know the Reference ID is a critical piece of shipping documentation, just like a tracking number.

If you need help identifying which of your products fall under this requirement or Reese's Law, or need a strategy for the Product Registry, Email me.