If you import a consumer product into the United States that is covered by a Consumer Product Safety Commission (CPSC) rule, ban or standard, the importer must issue a written certificate saying it complies: a Children's Product Certificate (CPC) for children's products, or a General Certificate of Conformity (GCC) for other regulated products. The big change is that, since 8 July 2026, the importer of most such products also has to eFile the certificate data with US Customs and Border Protection (CBP) when the entry is filed. As of November 2026, CPSC says it is sending warnings rather than rejecting entries for missing data, but it can still hold or seize non-compliant goods. This guide sits alongside our explainers on the importer of record and the ISF 10+2.
Which products need a CPC or GCC?
A certificate is required for finished consumer products that are subject to a CPSC product safety rule, ban or standard (or similar rules under other statutes CPSC enforces). Which certificate you need depends on who the product is for:
- CPC: products designed or intended primarily for children aged 12 or younger. These must be tested by a third-party laboratory that CPSC has accepted.
- GCC: other regulated consumer products. These must be based on testing or a reasonable testing program, and CPSC does not require a CPSC-accepted lab for them.
Products with no applicable CPSC rule do not need either certificate, but that does not make them unregulated: other agencies (for example the FDA for food and cosmetics) have their own filings. See our guide on FDA Prior Notice and FSVP for the food side. CPSC's Regulatory Robot is the tool it points businesses to for working out which rules apply to a product.
Who issues the certificate: the importer or the manufacturer?
This is the most common misconception. Many sellers assume "the factory certifies". Under 16 CFR 1110.7, for a product made outside the United States, the importer is the certifier and must issue the certificate. For a product made in the US, the domestic manufacturer is the certifier (unless the product is private labelled). A factory can supply test reports and a draft certificate, but the legal responsibility sits with the US importer, and that importer must be able to produce the supporting test records on CPSC's request.
CPSC describes the importer of a finished product as a party eligible to make entry, such as the owner, purchaser, consignee or an authorized customs broker. In practice the importer of record named on the entry is the party CPSC looks to, which is why who acts as importer of record matters so much here.
What must the certificate contain?
CPSC's guidance lists seven elements, which apply to both the CPC and the GCC (16 CFR Part 1110):
- Identification of the product, specific enough to match the certificate to that product only.
- Citation to each applicable CPSC rule, ban, standard or regulation, listed separately (including any exemption relied on).
- Name, mailing address and phone number of the certifier (the importer or domestic manufacturer).
- Contact for the person who keeps the test records.
- Date and place of manufacture.
- Date and place of testing (the most recent testing).
- Identification of the third-party lab that did the testing, where one was used.
The certificate and supporting test reports must be in English. Under the revised rule, an eFiled certificate also covers a single product only, and from 8 July 2026 the certificate data must identify any testing exclusion the importer relies on (CPSC's FAQ states this).
Third-party testing and the CPSC-accepted lab list
For children's products, the test report behind the CPC must come from a third-party laboratory accredited and accepted by CPSC for the specific rules being tested. CPSC publishes a searchable lab list, plus lists of accepted firewalled and governmental labs. Practical points:
- Check that the lab is accepted for each rule your product is tested to, not merely accredited in general.
- Where an exemption or determination means no testing is needed, a CPC is still required, citing the exemption instead of a lab.
- Keep the full test reports. The eFiled certificate carries the lab's identity and dates, not the report itself.
Tracking labels on children's products
Separate from the certificate, section 14(a)(5) of the Consumer Product Safety Act requires manufacturers (including importers of foreign-made goods) to put permanent distinguishing marks on children's products and, to the extent practicable, their packaging, so the origin of the product can be traced (typically source, production date and batch or run information). CPSC's guidance says existing permanent marks can count, a Registered Identification Number alone does not, and the law gives no small-business exemption. Even where the product cannot be marked, the packaging still should be.
The CPSC eFiling rule: what changed
CPSC's final rule on certificates of compliance was published in the Federal Register on 8 January 2025 (90 FR 1800, revising 16 CFR Part 1110). A correction notice followed in September 2025; check the current text on the Federal Register and eCFR. The key points, as stated on CPSC's eFiling FAQ in November 2026:
| Item | What CPSC says |
|---|---|
| Start date | 8 July 2026 for most imported regulated products |
| Foreign Trade Zones | 8 January 2027 for goods entered from an FTZ for consumption or warehousing |
| International mail | A CPSC bulletin of 1 September named 22 October 2026 for mail shipments filed under CBP Entry Type 13, but CBP's final rule of 22 October moved its mandatory mail date to 20 January 2027. Confirm the date that applies to you with CPSC and your broker |
| Shipment value | No minimum: a certificate is needed "regardless of the value of the imported shipment", including Section 321 shipments |
| Who files | The importer supplies the data; the broker transmits it in ACE |
| Enforcement | CPSC does not intend initially to have ACE send reject messages for missing data, only warnings |
The "no minimum value" point matters for small parcels: our guide on Section 321 and Type 86 entries explains that the duty-free low-value route is not a way around product safety filings.
What is filed in ACE: Full or Reference PGA Message Set
The certificate data travels in CBP's Automated Commercial Environment (ACE) as a CPSC Partner Government Agency (PGA) Message Set. There are two ways to do it:
- Full PGA Message Set: the importer gives the broker all the certificate data for each shipment: product ID, citation codes, manufacture date and place, test date, testing laboratory and point of contact.
- Reference PGA Message Set: the importer enters the certificate once in CPSC's Product Registry, then gives the broker three Certificate Identifiers (Certifier ID, Product ID and Version ID). This suits importers who bring in the same certified product repeatedly. The Registry is optional and does not talk to ACE itself.
The product ID must be a GTIN, SKU, UPC, model number, serial number, registered number or alternate ID. CPSC also encourages "disclaim" messages for products that have no certificate requirement, which may help risk scores. For mail shipments the data goes in through Entry Type 13 under the same Full or Reference options.
How CPSC targets shipments at the port
CPSC uses a Risk Assessment Methodology (RAM), required by section 222 of the Consumer Product Safety Improvement Act of 2008, which scores import entry lines using CBP entry data so investigators can pick higher-risk lines for examination. CPSC investigators work with CBP at ports, and CPSC says certificate data can change an entry's risk score, so complete and accurate filings may reduce holds and exams. Missing data does not currently trigger an automatic rejection, but it can leave a shipment looking riskier, and CPSC can ask CBP to hold or seize goods that lack required certificates or fail the rules.
What your customs broker needs from you
- The decision on which certificate type applies (CPC or GCC) and the list of rules cited.
- For a Full message set: product ID, manufacture date and place, test date, lab name and a point of contact, per product.
- For a Reference message set: your three Certificate Identifiers from the Product Registry.
- Evidence on request: test reports, which stay with you, not the broker.
- Clear instructions on products that need a disclaim rather than a certificate.
If you are unsure whether you need a broker at all, see Do You Need a Customs Broker?
Misconception: Amazon FBA sellers are not importers
Selling through Amazon does not move the importer's duties onto Amazon. If your company buys the goods overseas and ships them to a fulfilment centre, you (or the party named on the entry) are the importer and the certifier. A freight forwarder who books the ocean leg is not the certifier either. Marketplaces and forwarders may ask to see your certificate, but they do not issue it for you. Our guide to freight forwarders for ecommerce and Amazon FBA covers the logistics side.
What to do next
- List each product you import and check, with CPSC's Regulatory Robot, whether any CPSC rule, ban or standard applies and whether it is a children's product.
- Get test reports from a CPSC-accepted lab (children's products) or run a reasonable testing program (general products), and confirm the manufacture and test details.
- Issue one certificate per product in your name as importer, in English, with the seven elements, and decide whether to use the Product Registry.
- Give your broker the data or Certificate Identifiers before the entry is filed, and check CPSC's eFiling page and CBP notices for updates before each season.
Need help moving regulated goods into the US? More than 29,300 logistics companies are searchable by country and service in the CargoLinked directory, and the public requests board lists freight that shippers have posted for forwarders to quote on directly.
This article is general information as of November 2026, not legal or customs advice. Rules and enforcement positions change; confirm the current requirements with the CPSC, CBP or a licensed customs broker or product-safety professional before relying on them.
