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CPSC Maintains Momentum on eFiling Requirements for Consumer Products

Client Alert | 1 min read | 08.27.25

A question often asked by consumer product companies these days is whether the eFiling requirements will go into effect as planned given the political upheaval at the U.S. Consumer Product Safety Commission (CPSC) and the dismissal of the three Democrat Commissioners. While that is an impossible question to answer with certainty, all signals suggest the requirements will be implemented on schedule for July 8, 2026.

On December 18, 2024, the CPSC―with a then-full roster of Commissioners―unanimously voted to approve a final rule to implement an eFiling system and revise existing certificate of compliance requirements for certain consumer products. The Final Rule, published on January 8, 2025 (revising 16 CFR Part 1110), requires the eFiling of certificates of compliance with U.S. Customs and Border Protection (CBP) at the time of filing entry for regulated, imported consumer products. 

Last month (July 2025), the CPSC issued new guidance on the eFiling aspect of the Rule (CPSC eFiling Guidance). In summary, the new guidance requires:

  • Each finished product certificate must describe only one product (16 CFR § 1110.13(a)).
  • The importer is required to submit certificate data upon filing entry into CBP’s Automated Commercial Environment (ACE), which already is set up to accept the data, for all CPSC-regulated merchandise.
  • The CPSC has a prepared message set for input of certificate information, and the submission can be transmitted as part of a weekly entry submission.

The CPSC has been holding virtual office hour sessions to explain and secure feedback on the new eFiling process.

Despite all of the upheaval at the CPSC, this new eFiling process seems to remain on track for implementation. Companies should stay the course to prepare for eFiling, which will take effect on July 8, 2026 for applicable CPSC regulated consumer products, except for products first imported into a foreign trade zone (FTZ) and then entered into the U.S. for which the Rule is effective on January 8, 2027. So, while the implementation is almost a year away, July 2026 will be here before we know it.

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