CPSC eFiling Explained: Certificates, ACE, and the 2027 Deadline

Published October 5, 2026

CPSC eFiling means the data from a product's certificate of compliance is filed electronically with U.S. Customs and Border Protection when the goods are entered, instead of the certificate sitting in a file until someone asks for it. It comes from CPSC's Certificates of Compliance rule, 16 CFR part 1110.

What the rule requires

For finished products made outside the United States and offered for import for consumption or warehousing, including entries from a foreign trade zone and shipments eligible for the de minimis exemption, the certifier must eFile the certificate data elements at the time of filing the entry (or entry and entry summary, if filed together) in ACE, CBP's Automated Commercial Environment. (Source: 16 CFR part 1110, certificates of compliance, 1110.13(a)(1).) For products imported by mail, the data goes into CPSC's Product Registry before the product arrives. (Source: 16 CFR part 1110, certificates of compliance, 1110.13(a)(1).)

For products made in the United States, nothing is filed at a border: the certificate must be issued on or before the date the product is distributed in commerce and be available to CPSC within 24 hours of a request. (Source: 16 CFR part 1110, certificates of compliance, 1110.13(a)(2).)

The dates

Both dates are in the final rule. (Source: CPSC final rule, Certificates of Compliance, 90 FR 1800 (January 8, 2025).) The January 8, 2027 date is the one still ahead for importers using foreign trade zones.

The seven certificate data elements

The rule sets what each finished product certificate must contain, (Source: 16 CFR part 1110, certificates of compliance, 1110.11(a).) and the Implementation Guide lists the same seven elements for eFiling: (Source: CBP and Trade Automated Interface Requirements: CPSC eFiling Implementation Guide, version 2.4.)

1. Product identification. At least one of GTIN, model number, registered number, serial number, SKU, UPC or an alternate identifier, with enough description to match the product to the certificate.
2. The rules it is certified to. Each applicable rule, ban, standard or regulation, listed separately, or the testing exclusion claimed.
3. The certifier. Name, street address, city, state or province, country, email and telephone.
4. The records contact. The person (or an always-staffed position) who keeps the test records, with the same contact details.
5. Date and place of manufacture. At least month and year, with the manufacturer's name and contact details.
6. Date and place of testing. The most recent test date and the lab or other party whose testing the certificate relies on.
7. The attestation. For eFiled certificates, it is built into the Product Registry and the message set.

The certifier remains legally responsible for the information even when it relies on another party to test, certify or enter data. (Source: 16 CFR part 1110, certificates of compliance, 1110.15.) Certificates and their supporting records are kept for at least five years. (Source: 16 CFR part 1110, certificates of compliance, 1110.17.) Component part certificates are not eFiled. (Source: 16 CFR part 1110, certificates of compliance, 1110.19.)

Full vs Reference PGA Message Set

There are two ways to get the data into the entry. Both satisfy the rule. (Source: CPSC final rule, Certificates of Compliance, 90 FR 1800 (January 8, 2025).)

The descriptions are from the Implementation Guide, (Source: CBP and Trade Automated Interface Requirements: CPSC eFiling Implementation Guide, version 2.4.) and the three identifiers are also listed in the Product Registry FAQ. (Source: CPSC Product Registry Frequently Asked Questions, version 1.4.) The Implementation Guide also describes a disclaim message, used to tell CPSC that a product imported under a flagged tariff code does not require certificate data. (Source: CBP and Trade Automated Interface Requirements: CPSC eFiling Implementation Guide, version 2.4.)

What is at stake

Under the Consumer Product Safety Act, a product offered for import that is not accompanied by a required certificate shall be refused admission. (Source: 15 U.S.C. 2066, imported products, (a).) Civil penalties under the Act can reach $120,000 for each violation and $17,150,000 for a related series of violations, under the inflation adjustment CPSC published on December 1, 2021, for violations after January 1, 2022. (Source: CPSC, Civil Penalties; Notice of Adjusted Maximum Amounts (December 1, 2021).) Those are maximums, not set fines.