CPSC eFiling is now LIVE

Effective July 8th, 2026, BEFORE products enter U.S. commerce, importers of regulated consumer products must now submit compliance certificates electronically as part of CPSC's eFiling requirement.

Client Update: July 2026. Disclaimer.

By: Neal Cohen and Boaz Green

Neal Cohen Law LLC

July 8, 2026

Today is the day that CPSC’s mandatory eFiling program goes into effect. CPSC has been working towards this day for over 15 years.

We previously sent this detailed article about eFiling and we urge you to review it if you are not familiar with this requirement.

We have heard some reports of the CPSC’s Product Registry Database not working for some users as intended.

We have also seen some bad advice being provided by customs brokers (even major ones) and freight forwarders regarding the flagging of certain HTS codes for eFiling.

To be clear, while all children’s products require eFiling, only some non-children’s products require eFiling.

CPSC’s release of HTS codes has, perhaps, created more confusion than it has solved. Just because an HTS code is on CPSC’s HTS code list does NOT necessarily mean that eFiling (for a non-children’s product) is required. The CPSC’s list only identifies HTS codes that may be impacted.

Emphasizing that point, U.S. Customs sent the following message this morning (below). In it, they clearly state that importers are allowed by CPSC regulation to send no CPSC message even if the HTS code is flagged by CPSC. They also note that, for now, CPSC is not requesting that CBP reject or refuse entries for missing PGA Message Set data.

Finally, don’t forget that the CPSC’s list itself may be incomplete. The importer is always responsible for ensuring compliance with all applicable requirements.

If you have any doubts about your company’s obligations under the new eFiling requirement, please reach out to us and we can provide you with the correct guidance

Starting July 8, 2026, the Consumer Product Safety Commission (CPSC) will be implementing its PGA Message Set (eFiling).

This CSMS is being sent by CPSC to clarify that while other Partner Government Agency (PGA) integrations may require that integrated Automated Broker Interface (ABI) software prevent the filing of entries with missing or incomplete data for Harmonized Tariff Schedule (HTS) codes with “MUST” flags, CPSC has chosen not to implement such a requirement. As stated in the final rule and published in guidance on CPSC's website, CPSC is not requesting that CBP reject entries for missing PGA Message Set data.

As such, software providers are not expected to require that filers provide a PGA Message Set for CPSC on any HTS code, regardless of the presence of a CP1 or CP2 flag. In other words, filers are allowed by CPSC regulation to send no CPSC message even if the HTS code is flagged as CP1 or CP2. However, CPSC does encourage the implementation of advisory messages to ensure that filers are aware that PGA data is, or may be, required on their submissions (depending on the HTS code).