When did CPSC eFiling become mandatory?

CPSC's Final Rule took effect for most imported consumer products on 8 July 2026. For consumer products imported into a Foreign Trade Zone and subsequently entered for consumption or warehousing, the requirements take effect on 8 January 2027.

Will CBP deny entry if the certificate data is not eFiled?

CPSC states that at this time it does not intend to request that CBP deny entry solely for failure to eFile, and does not intend initially to have ACE send reject messages for missing data, only warning messages. It also states that it will continue to enforce certificate requirements and to request seizure of non-compliant products, and that it adjusts an entry line's risk score based on the certificate data filed. Warning-only messages are about the filing, not about the certificate obligation.

What is the difference between a Full and a Reference PGA Message Set?

For a Full PGA Message Set the importer provides his broker with the seven required product certificate data elements and the broker files them. For a Reference PGA Message Set the importer pre-enters the certificate data into CPSC's Product Registry and gives the broker the certificate identifiers instead: Certifier ID, Product ID and Version ID. CPSC describes the reference route as preferable when the same product is imported repeatedly against the same certificate.

Does the de minimis exemption apply to eFiling?

No. CPSC states that any product requiring certification must have an eFiled certificate regardless of the value of the shipment, and that there is no Section 321 de minimis exemption for eFiling.

Does CertSeven file anything with CBP?

No. CertSeven checks a certificate against the content requirements of 16 CFR 1110.11(a) and publishes one at a permanent verifiable address. The eFiling into ACE is done by the importer or his customs broker. Publishing here meets the conditions 16 CFR 1110.9(c) sets for an electronic certificate, which is how the furnishing and availability duties in 16 CFR 1110.13(b) and (c) can be met; it is not the entry filing that 1110.13(a)(1) requires.

CPSC eFiling · mandatory since 8 July 2026

What your customs broker needs for CPSC eFiling

Since 8 July 2026, certificate data for regulated consumer products must be eFiled into CBP's ACE when the entry is filed. The importer gives his customs broker either the seven certificate data elements (a Full PGA Message Set) or, having pre-entered the certificate in CPSC's Product Registry, the certificate identifiers (a Reference PGA Message Set). The broker transmits it. There is no de minimis exemption.

The two things that are both called “seven”

These are routinely confused, and confusing them is how an importer ends up believing a certificate is filed when it is not, or that a filing replaces a certificate.

The seven content requirements of 16 CFR 1110.11(a) are what has to appear on the certificate. That is what the free checker tests, and what changed on 8 July 2026.
The seven certificate data elements of the Full PGA Message Set are what the broker transmits into ACE. They are listed below, in CPSC’s own naming.

The seven data elements CPSC names

For a Full PGA Message Set, CPSC states that the importer provides his broker with the seven required product certificate data elements for the imported product, and the broker files them in the CPSC PGA Message Set.

Data element	Where it comes from on the certificate
Product ID	The identifier for the product, which 16 CFR 1110.11(a)(1) also requires on the certificate.
Citation Codes	CPSC's codes for the rules certified to, corresponding to the rules listed under (a)(2).
Manufacture Date	The date under (a)(5).
Manufacture Place	The place under (a)(5).
Product Test Date	The most recent test date under (a)(6).
Testing Laboratory	The testing body under (a)(6).
Point of Contact	The contact CPSC can reach about the certificate.

A certificate published here carries a data sheet setting out its facts one row per paragraph, to print or download as a spreadsheet and send on. It is the information, not a message set: CertSeven does not transmit anything to CBP, and the Citation Codes CPSC uses are assigned by CPSC rather than by us.

Warning messages are not the same as no obligation

CPSC states that at this time it does not intend to request that CBP deny entry solely for failure to eFile, and does not intend initially to have ACE send reject messages for missing data — only warning messages. The same answer states that CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products, and that it adjusts an entry line’s risk score based on the certificate data filed.

So the leniency is about the transmission, not about the certificate. A product that needs a certificate still needs one that says what the rule requires.

Questions

When did CPSC eFiling become mandatory?: CPSC's Final Rule took effect for most imported consumer products on 8 July 2026. For consumer products imported into a Foreign Trade Zone and subsequently entered for consumption or warehousing, the requirements take effect on 8 January 2027.
Will CBP deny entry if the certificate data is not eFiled?: CPSC states that at this time it does not intend to request that CBP deny entry solely for failure to eFile, and does not intend initially to have ACE send reject messages for missing data, only warning messages. It also states that it will continue to enforce certificate requirements and to request seizure of non-compliant products, and that it adjusts an entry line's risk score based on the certificate data filed. Warning-only messages are about the filing, not about the certificate obligation.
What is the difference between a Full and a Reference PGA Message Set?: For a Full PGA Message Set the importer provides his broker with the seven required product certificate data elements and the broker files them. For a Reference PGA Message Set the importer pre-enters the certificate data into CPSC's Product Registry and gives the broker the certificate identifiers instead: Certifier ID, Product ID and Version ID. CPSC describes the reference route as preferable when the same product is imported repeatedly against the same certificate.
Does the de minimis exemption apply to eFiling?: No. CPSC states that any product requiring certification must have an eFiled certificate regardless of the value of the shipment, and that there is no Section 321 de minimis exemption for eFiling.
Does CertSeven file anything with CBP?: No. CertSeven checks a certificate against the content requirements of 16 CFR 1110.11(a) and publishes one at a permanent verifiable address. The eFiling into ACE is done by the importer or his customs broker. Publishing here meets the conditions 16 CFR 1110.9(c) sets for an electronic certificate, which is how the furnishing and availability duties in 16 CFR 1110.13(b) and (c) can be met; it is not the entry filing that 1110.13(a)(1) requires.

Start with the certificate itself

Whichever route your broker uses, the data has to come from a certificate that carries what 16 CFR 1110.11(a) requires. Paste yours and see, requirement by requirement, what is present and what is missing.

Check a certificate

The statements about eFiling procedure on this page are drawn from CPSC’s eFiling Frequently Asked Questions, last verified 2026-08-26. CertSeven is not a customs broker, does not file with CBP or ACE, and gives no legal advice. Under 16 CFR 1110.15 the finished product certifier remains legally responsible for the certificate.