The short version
- Since July 8, 2026, most imported finished products regulated by the United States Consumer Product Safety Commission that already require certification must have certificate data filed electronically. Covered imports handled through an ordinary Customs entry are filed at entry; covered mail imports use the Product Registry before arrival.
- Start with the exact product. Not every import needs a certificate, but a low-value shipment does not escape eFiling when its product does.
- For an ordinary broker-filed entry, Full sends certificate data with the entry; Reference sends three Product Registry identifiers.
- The finished-product certifier is the company or person named on and responsible for the certificate. For a covered product made outside the United States, that is generally the importer unless a specific rule says otherwise.
A testing report in a folder is no longer the whole handoff
Your supplier sends a test report. You approve the purchase order. Then, after the cargo starts moving, the customs broker asks for certificate data you have never seen.
That timing was always uncomfortable. It is now an avoidable import risk.
The United States Consumer Product Safety Commission, or CPSC, made electronic filing mandatory on July 8, 2026 for most imported finished products it regulates that require certification.
This does not replace the underlying testing rules. Revised federal rules also update what a certificate contains, including a certifier attestation and any claimed testing exclusions.
Covered imports handled through an ordinary Customs entry are filed at entry. Covered mail imports instead require Product Registry entry before arrival.
Our operational recommendation is earlier: settle the certificate and handoff before the shipment leaves.
First decide whether the exact product needs a certificate
The new requirement is not a blanket rule for everything sold on Amazon.
It applies when the finished product is subject to a CPSC-enforced safety rule, ban, standard, or regulation and that product must be certified.
Covered children's products generally use a Children's Product Certificate. It is supported by testing from a CPSC-accepted lab, subject to allowed exclusions or determinations. Covered general-use products use a General Certificate of Conformity.
Do not decide coverage from an Amazon category or tariff code alone. Check the product's features and intended use against the governing rule.
If the answer is unclear, stop. Ask a qualified testing lab or product-safety adviser to identify the rules and test support. A broker can file data, but should not be expected to make that safety decision.
Certificate data—or Registry identifiers—must enter the filing workflow
A finished-product certificate identifies the product and applicable safety rules. It also names the certifier and records contact, gives manufacturing and testing details or exclusions, and includes an attestation.
For ordinary broker-filed Customs entries, there are two main electronic filing paths:
- Full Message Set: certificate data is submitted with the Customs entry.
- Reference Message Set: three identifiers point to a certificate stored in the CPSC Product Registry. The broker files the Certifier ID, Product ID, and Version ID with the entry.
The Product Registry is designed for repeat imports that use the same certificate data. It is optional if you use the Full Message Set.
One detail matters: saving a certificate in the Product Registry does not send it to Customs. For the Reference path, the importer still has to give the three identifiers to the broker for filing.
Filing work can be delegated; responsibility cannot
The importer, customs broker, or another authorized party can enter the data. That does not transfer responsibility for the certificate.
For covered products made outside the United States, the importer is generally the finished-product certifier unless a specific rule provides otherwise. That certifier remains responsible for the certificate's validity, accuracy, completeness, and availability.
Do not assume a small parcel gets a pass. If its product already requires certification, there is no shipment-value or Section 321 exemption from the eFiling requirement.
As of September 10, 2026, the CPSC says it initially intends missing eFiling data to generate warnings rather than automatic entry rejection. Ordinary certificate enforcement still applies. Treat that as a current implementation posture, not permission to ship incomplete records.
One timing exception is worth flagging: covered withdrawals from a Foreign Trade Zone use a January 8, 2027 applicability date.
Run this five-step check before freight moves
Use this as an import-readiness gate, not a product-specific legal opinion:
- Classify the exact finished product. Record its materials, intended age and use, claims, and manufacturing details.
- Confirm the rules and support. Identify the applicable CPSC citations, certificate type, testing records, and any legitimate testing exclusions. Have a qualified testing lab or product-safety adviser confirm those items in writing.
- Name the owner. Write down the finished-product certifier, records contact, and the person responsible for approving the certificate data.
- Choose the filing path. Decide whether the broker will send the Full Message Set or the three Reference identifiers. Assign who creates the Registry record, who checks it, and who sends the filing data.
- Dry-check the handoff. Before shipment, send the broker the certificate packet and ask them to confirm the intended entry path and required fields.
For a Reference filing, the required entry data is concrete: Certifier ID, Product ID, and Version ID. Ask the broker to confirm that those identifiers will be carried into the Customs entry.
As an operational control, also keep or share the approved certificate. A screenshot showing a Registry record is not enough.
Keep the certificate and supporting records for at least five years from the certificate creation date.
The output of this check should fit on one page. List the exact product, applicable rules, certificate type, testing support, certifier, records contact, filing path, and broker owner. Add the three identifiers if Reference is used.
Research the product, then pause for compliance
Use Launch Fast to research demand, competition, and product opportunities. When an imported product reaches your shortlist, screen whether certification may apply before the purchase order.
If certification applies, do not release the order until the supplier, testing lab, finished-product certifier, and customs broker handoff is documented. Launch Fast helps you decide what may be worth selling; it does not determine whether a product is covered or compliant.
Official guidance
Checked September 10, 2026: CPSC eFiling FAQ and 16 CFR Part 1110. Check the current guidance with your broker before shipping.
