The U.S. Consumer Product Safety Commission (CPSC) eFiling program will require the electronic submission of certificate data from Children’s Product Certificates (CPCs) and General Certificates of Conformity (GCCs) for regulated consumer products through U.S. Customs and Border Protection (CBP)’s Automated Commercial Environment (ACE). This requirement applies to consumption entries beginning July 8, 2026, and to Foreign Trade Zone (FTZ) filing type 06 entries on the weekly estimate beginning January 8, 2027.

NAFTZ has been engaging with CPSC on this concept since 2015—initially as part of the broader Partner Government Agency (PGA) implementation in ACE, and continuing through the publication of the final rule in late 2024. While CPSC acknowledged that FTZs are unique—and that the most appropriate time to present certificate data for finished goods would be at the time of admission—the final rule ultimately requires filing at entry.

This creates a significant operational challenge for FTZs. CPSC expects certificate data to be associated with the actual physical item being shipped, not the FIFO inventory layer. In discussions, CPSC acknowledged this may require submitting a sub-line of certificate data for every possible instance of a certificate  for that item in inventory on the weekly estimate. For many companies, this could mean multiple sub-lines per article per entry line—a level of complexity that is difficult to overstate.

Consider, for example, the implications of a targeted enforcement action. If CPSC were to flag a particular entry line, would you be able to identify all possible physical items in inventory that could ship—and link each one to the appropriate certificate? For many operators, this level of traceability does not currently exist.

If your head is spinning, you’re not alone.

The association continues to advocate on this issue ahead of the January 2027 implementation date. We are seeking additional support—including potential congressional pressure—for a delay until ACE can accommodate filing at the time of admission via the e214.

It is important to note that certification itself is not a new requirement. Since January 1, 2012, manufacturers and importers of regulated consumer products have been required to maintain CPCs or GCCs and provide them upon request. What is new is the requirement to transmit specific certificate data elements electronically in ACE.

CPSC has published a list of HTS codes that will be flagged for reporting in ACE. Below are representative product categories; however, this list is not exhaustive. Importers remain responsible for determining which regulations apply to their goods and whether eFiling is required:

• All-Terrain Vehicles (ATVs)
• Bicycle Helmets and Bicycles
• Button Cell and Coin Batteries
• CB Antennae
• Carpets and Rugs
• Carriages and Strollers
• Child Chairs
• Cigarette and Multipurpose Lighters
• Clothing
• Drywall
• Fireworks
• Gates and Enclosures
• Imitation Jewelry
• Infant Sleep Products
• Lawn Mowers
• Matchbooks
• Mattresses
• Other Children’s Furniture
• Pacifiers
• Poison Prevention Packaging
• Shoes
• Toys

Importers may choose between two filing options:

Full PGA Message Set (7 data elements transmitted):

• Product ID
• Citation Codes
• Date of Manufacture
• Place of Manufacture
• Product Test Date
• Testing Laboratory
• Point of Contact

Reference PGA Message Set (3 data elements transmitted, after pre-loading certificate data into the CPSC Product Registry):

• Product ID
• Version
• Certifier ID

What You Can Do to Get Ready

• Review CPSC’s eFiling webpage
• Evaluate how you will obtain and compile certificate data
• Determine where and how this data will be stored
• Assess how the data will be shared with your Inventory Control and Recordkeeping System (ICRS)
• Engage with your customs broker—have they participated in pilots or voluntary filing, and what insights can they provide?
• Talk to your ICRS software provider to understand what capabilities they are building in preparation for eFiling

Closing Thoughts

CPSC eFiling represents a fundamental shift from document retention to real-time data submission—and for FTZ operators, the implications are particularly complex. While advocacy efforts continue, companies should assume the current rule will stand and begin preparing now. Early engagement with internal stakeholders, brokers, and system providers will be critical to managing risk and avoiding disruption. Those who invest the time today to understand their data, systems, and processes will be far better positioned to navigate this transition—and to respond confidently when enforcement begins.