CPSC eFiling Is Now Mandatory: What Importers File at Entry, and the Dates Still Ahead

Who this is for: import, compliance and supply chain leads at consumer goods, children's product and apparel companies that bring CPSC-regulated products into the United States, and at e-bike, e-scooter and hoverboard brands following CPSC's proposed battery rule.

What changed on July 8, 2026

CPSC's final rule on certificates of compliance, published January 8, 2025 at 90 FR 1800, revised 16 CFR part 1110 and moved certificate data into the entry itself. For finished products made outside the United States and offered for import for consumption or warehousing, the certifier must eFile the certificate data elements "at the time of filing the entry, or the time of filing the entry and entry summary, if both are filed together, in ACE" (16 CFR 1110.13(a)(1)).

Before the rule, importers had to hold a certificate and produce it when CPSC or CBP asked. Now the data arrives with the entry, where CPSC can use it to score the shipment's risk. A September 2025 correction (90 FR 45917) restated the dates as one effective date, July 8, 2026, and two applicability dates, and CPSC said the correction "has no substantive effect" on the dates by which products must comply.

The rule text also covers finished products eligible for the de minimis duty exemption, but CBP has suspended that exemption indefinitely (91 FR 37789 and 91 FR 37801), so low-value shipments now need a formal or informal entry. Products imported by mail work differently: the certifier enters the certificate data in CPSC's Product Registry before the shipment arrives. The rule does not change what has to be tested. Part 1110 "does not address the type or frequency of testing necessary to support a certificate" (16 CFR 1110.1).

The next date: foreign trade zone entries from January 8, 2027

For CPSC-regulated products imported into a foreign trade zone and later entered for consumption or warehousing, the rule applies from January 8, 2027. If you hold regulated goods in a zone, plan for certificate data to travel with entries from the zone made on or after that date.

Who has to eFile

• The importer certifies. For a finished product made outside the United States, "the importer, as defined in this part, is the finished product certifier" (16 CFR 1110.7(a)). The importer is the importer of record eligible to make entry.
• When a customs broker is the importer of record. The broker may identify the owner, purchaser or consignee that authorized the entry as the party responsible for the CPSC certificate, as part of the certificate data it files (16 CFR 1110.3). If it does not, CPSC has said it can hold the broker legally responsible for the certificate data.
• Relying on others does not shift responsibility. A certifier may rely on another party to test, to certify or to enter data in the Product Registry, but it "remains legally responsible for the information in a finished product certificate, including its validity, accuracy, completeness, and availability" (16 CFR 1110.15).
• Children's products, such as toys, cribs, strollers and children's clothing, need a Children's Product Certificate based on testing by a CPSC-accepted third party lab (15 U.S.C. 2063(a)(2)).
• Other regulated products, such as adult bicycles, mattresses and disposable or novelty lighters, need a General Certificate of Conformity based on a test of each product or a reasonable testing program (15 U.S.C. 2063(a)(1)).
• Records. Certifiers keep certificates and the supporting test records for at least five years (16 CFR 1110.17).

What the certificate data must include

Under 16 CFR 1110.11(a), each finished product certificate must include:

1. The product, with at least one unique identifier (GTIN, model number, registered number, serial number, SKU, UPC or an alternate identifier) and a description that matches the product to the certificate.
2. Each CPSC rule, ban, standard or regulation the product is certified to, listed separately.
3. The certifier's name, street address, city, state or province, country, email and phone number.
4. The person who keeps the supporting records for the certifier, with the same contact details. A position title is allowed if the position is always staffed and responsive to CPSC's requests.
5. The month and year, and the place, where the product was manufactured, produced or assembled, including the manufacturer's name and contact details.
6. The most recent date and place of testing, including each third party lab or other party whose testing the certificate relies on.
7. The certifier's attestation. For eFiled certificates, the attestation is built into the Product Registry and CPSC's message set.

If you rely on a statutory or regulatory testing exclusion, the certificate names the exclusion in place of a test date and place for that rule (16 CFR 1110.11(c)). Check that the identifier on each certificate matches how the product appears on the commercial invoice and packing list, so the data and the documents describe the same item.

Two ways to send the data

CPSC's eFiling system accepts certificate data in two forms. With the Full PGA Message Set, every certificate data element goes to CBP through ACE with each entry. With the Reference PGA Message Set, the importer enters the certificate data in CPSC's Product Registry ahead of time, and the entry carries a reference to it. The reference route saves retyping the same data for products that are imported again and again. Mail shipments must use the Product Registry.

What happens when certificate data is missing

In the final rule, CPSC said: "As a matter of enforcement discretion, at least in the initial stages of eFiling, CPSC in general does not intend to request that CBP deny entry of products into the United States solely based on a failure to provide eFiled certificate data."

That is not a grace period. In the same rule, CPSC said a missing or false certificate "will affect a shipment's risk score, resulting in a higher likelihood of the shipment being held for an exam," and that it will keep enforcing certificate requirements by refusing admission or asking CBP to seize noncompliant products. The statute is plain: a product "shall be refused admission" if it fails an applicable consumer product safety rule or is not accompanied by a required certificate (15 U.S.C. 2066(a)).

Failing to furnish a required certificate, or issuing a false certificate when, in the exercise of due care, the certifier has reason to know it is false or misleading in any material respect, is also a prohibited act under 15 U.S.C. 2068(a)(6). For importers, a hold also costs time: an exam, storage and demurrage while the goods wait, and a launch or retailer date put at risk.

Proposed: a mandatory battery standard for e-bikes, e-scooters and hoverboards

On June 24, 2026, CPSC proposed a mandatory safety standard for lithium-ion batteries and the electrical systems of micromobility products (91 FR 38162, proposed 16 CFR part 1265). It is a proposal, not a final rule, so nothing has to comply yet. If it is finalized, covered products would need a certificate citing the new rule, and that certificate data would be eFiled at entry like any other.

What it would cover

• E-bikes, including pedal-assist and throttle models; e-scooters, both stand-up and seated; self-balancing scooters (hoverboards); e-skateboards; e-unicycles; and hybrids of these.
• Battery packs sold separately as replacements, aftermarket battery chargers, and the components of e-bike conversion kits.
• Not covered: children's battery-powered ride-on toys, all-terrain vehicles, off-highway vehicles, golf cars, vehicles NHTSA treats as motor vehicles, and mobility scooters for medical use.

What it would require

• E-bikes would have to meet UL 2849 (2020 edition). E-scooters, hoverboards and the other personal e-mobility products would have to meet UL 2272 (2024 edition). Battery packs sold on their own would have to meet UL 2271 (2023 edition). Aftermarket chargers for e-bikes would have to meet section 23 of UL 2849 plus CPSC's charging temperature requirement, and chargers for other products would have to meet section 11 of UL 2272.
• CPSC adds requirements on top of the UL standards, including battery enclosures that cannot be opened with common household tools, a battery management system that blocks charging when a cell is hotter than the manufacturer's limit, and reverse polarity tests. A current UL listing on its own may not show compliance with these additions.
• E-bikes would carry a warning that homemade batteries have caused fire and death, and separately sold battery packs and aftermarket chargers would be marked with the product and model they are meant for.

Certification and testing

As with other CPSC rules, the importer would certify imported products. Children's models would need testing by a third party lab accepted by CPSC for the new rule; the proposal adds the rule to the list that labs can be accepted for (16 CFR 1112.15(b)(58)). Other models would not need a third party lab, but each would need a General Certificate of Conformity based on testing, first or third party, or on a reasonable testing program.

Timing, and a cap on importing ahead of the rule

• Products "manufactured after" a date 180 days after a final rule is published would have to comply. The trigger is the manufacture date, not the import date.
• During those 180 days, manufacturers and importers could not make or import noncompliant products at more than 120 percent of their average monthly volume over the 13 months before the final rule is published (proposed 16 CFR 1265.8).
• Written comments closed August 24, 2026. CPSC will hear oral comments at a virtual meeting at 10 a.m. Eastern on October 21, 2026. Requests to speak, with the written text of the presentation, are due to the Office of the Secretary by 5 p.m. Eastern on October 15, 2026, and presenters must pre-register by the same time (91 FR 63208). Each presentation is limited to five minutes and to the scope of the proposal.

Why CPSC proposed it

CPSC says it knows of 227 incidents from 2019 through 2023, involving fires, explosions, gas releases, burns, overheating and smoke inhalation, that the proposed rule could potentially have prevented. Ninety of them involved 39 deaths and 181 injuries, and 120 (53 percent) happened while the product was plugged in and charging. CPSC also ran 29 voluntary recalls of micromobility products for fire, overheating and smoke inhalation hazards from January 2016 through November 2024.

It is also an import story. CPSC staff identified 179 firms that make or supply e-bikes to the U.S. market and said: "Most of these firms import products manufactured in China." Staff also found that "Nearly all eScooters are imported from China or Taiwan" and that "nearly all eBike batteries are manufactured overseas."

What e-bike, e-scooter and hoverboard importers can do now

• Collect the UL 2849, UL 2272 or UL 2271 test reports behind each model and battery pack you import, and check that they cover the exact models on your purchase orders.
• Map every separately sold battery pack and charger to the products and models it is sold for.
• Plan import volumes with the proposed 120 percent cap in mind, because it would start on the day a final rule is published.
• To be heard at the October 21 meeting, send the request and the written text, and pre-register, by 5 p.m. Eastern on October 15.

What to do now, for every regulated product

1. List every SKU that needs a certificate, and whether it needs a Children's Product Certificate or a General Certificate of Conformity.
2. Check each certificate against the seven data elements in 16 CFR 1110.11, starting with the unique identifier.
3. Choose between the full message set and Product Registry references, and agree with your filer who enters the data and when.
4. If you use a foreign trade zone, have certificate data ready for entries from the zone on or after January 8, 2027.
5. Keep certificates and supporting records for at least five years.
6. Build testing lead time into production schedules for new or changed products.

Children's apparel importers: see our guide to importing children's clothing after the July 8, 2026 CPSC eFiling mandate and the printable children's clothing import checklist.

Frequently asked questions

Is CPSC eFiling mandatory now?

Yes. Since July 8, 2026, importers of finished products that need a CPSC certificate must eFile the certificate data in ACE when they file the entry. Products entered from a foreign trade zone for consumption or warehousing follow on January 8, 2027.

Who is responsible for CPSC eFiling when a customs broker is the importer of record?

The importer of record is the certifier. If the importer of record is a customs broker, the broker may identify the owner, purchaser or consignee that authorized the entry as the party responsible for the certificate, as part of the data it files. If it does not, CPSC can hold the broker legally responsible for the certificate data. A certifier that relies on another party to enter data stays legally responsible for it.

What data does a CPSC certificate need?

Under 16 CFR 1110.11, a unique product identifier such as a GTIN, model number or SKU; each applicable rule, listed separately; the certifier's contact details; the records keeper's contact details; the date and place of manufacture; the most recent date and place of testing, including the lab; and the certifier's attestation.

What happens if certificate data is missing at entry?

CPSC said that, at least in the initial stages of eFiling, it generally does not intend to ask CBP to deny entry solely because eFiled data is missing. Missing or false data still affects the shipment's risk score and makes an exam more likely, and CPSC can refuse admission or ask CBP to seize noncompliant products.

Is the CPSC e-bike battery rule final?

No. CPSC proposed it on June 24, 2026, and written comments closed August 24, 2026. CPSC will hear oral comments on October 21, 2026. If a final rule is published, products manufactured more than 180 days later would have to comply.

Would e-bike and e-scooter batteries need third party testing?

Under the proposal, only children's models would need testing by a CPSC-accepted third party lab. Other models would need a General Certificate of Conformity based on testing, first or third party, or on a reasonable testing program.

Does the proposed battery rule limit imports before it takes effect?

Yes, as proposed. In the 180 days between a final rule and its effective date, manufacturers and importers could not make or import noncompliant products at more than 120 percent of their average monthly volume over the 13 months before the final rule.

Related guides

• Pre-entry document review before the U.S. customs entry
• Importing children's clothing: new CPSC rules
• Children's clothing import checklist
• USDA import permits, ISPM 15 and Lacey Act declarations
• FDA import compliance

Sources and limits

• CPSC, Certificates of Compliance final rule, 90 FR 1800 (January 8, 2025), and correction, 90 FR 45917 (September 24, 2025).
• 16 CFR part 1110, as amended effective July 8, 2026: sections 1110.1, 1110.3, 1110.7, 1110.11, 1110.13, 1110.15 and 1110.17.
• CPSC, Safety Standard for Lithium-Ion Batteries Used in Micromobility Products and Electrical Systems of Micromobility Products Containing Such Batteries, proposed rule, 91 FR 38162 (June 24, 2026), and announcement of opportunity for oral presentation of comments, 91 FR 63208 (October 5, 2026), Docket CPSC-2025-0012.
• CBP interim final rules suspending the de minimis exemption: 91 FR 37789 (all modes other than mail, effective June 24, 2026) and 91 FR 37801 (mail, effective July 24, 2026).
• Consumer Product Safety Act: 15 U.S.C. 2063 (certificates), 15 U.S.C. 2066 (refusal of admission) and 15 U.S.C. 2068 (prohibited acts).

Not covered here: test methods for specific products, state and local e-bike battery laws, rules for shipping lithium batteries as dangerous goods, and whether a particular product is a children's product. This guide is operational guidance, not legal advice.

Last reviewed: October 3, 2026.