The U.S. Consumer Product Safety Commission (CPSC) has finalized an important regulatory change that will affect how compliance documentation is handled for imported consumer products. Under the new rule, importers must electronically file key information from their Certificates of Compliance (CoCs) at the time of customs entry, replacing the long-standing practice of maintaining certificates internally and providing them only upon request.
This move toward mandatory electronic filing—known as “e-Filing”—is intended to modernize the CPSC’s oversight process and improve how product safety risks are identified and managed at U.S. ports of entry.
What Is Changing
Previously, importers were responsible for creating and retaining Certificates of Compliance to demonstrate adherence to applicable CPSC safety rules, but those certificates were not submitted with entry documentation. Under the new e-Filing rule, essential certificate data must now be transmitted electronically through U.S. Customs and Border Protection’s Automated Commercial Environment (ACE) system when an entry is filed.
The required e-Filed information includes, at a minimum:
-
Identification of the finished product
-
The party certifying compliance
-
Applicable CPSC safety rules and standards
-
Manufacturing and testing location and dates
-
Contact information for the compliance records holder
Providing this information earlier in the import process allows the CPSC to better assess risk, focus inspections on higher-risk products, and reduce unnecessary delays for compliant shipments. The rule does not introduce new testing or safety requirements; rather, it changes how existing compliance information must be submitted and managed.
Implementation Timeline
To allow industry sufficient time to prepare, the CPSC has adopted a phased implementation schedule:
-
Mandatory e-Filing for most imported consumer products begins July 8, 2026
-
Products first entered into a Foreign Trade Zone and later released into U.S. commerce will be subject to mandatory e-Filing starting January 8, 2027
Ahead of these dates, the CPSC is offering a voluntary participation stage that allows a limited number of importers to begin e-Filing early. This phase is designed to help companies test systems, refine internal workflows, and coordinate with customs brokers before the rule becomes enforceable.
Why e-Filing Matters for Importers
Although e-Filing may appear to be an administrative update, it has meaningful operational implications. Certificate data will now be directly linked to customs entries, meaning incomplete or inaccurate submissions can result in delays, increased scrutiny, or shipment holds. Over time, the quality and consistency of e-Filed data may also influence an importer’s risk profile and inspection frequency.
As a result, Certificates of Compliance can no longer be treated as static documents stored after production. Importers must ensure that compliance data is accurate, standardized, and readily available at the time of entry, often requiring closer coordination between sourcing teams, testing laboratories, compliance personnel, and customs brokers.
Preparing for the Transition
Companies should begin reviewing whether their current compliance and data management systems are capable of supporting electronic submission requirements. This includes confirming that product and testing information is consistently formatted and easily accessible, and that internal teams understand how certificate data will flow into ACE filings.
Early engagement—such as registering for a CPSC Product Registry business account or participating in the voluntary e-Filing stage—can help reduce the risk of disruption once e-Filing becomes mandatory.
How HQTS Supports e-Filing and CPSC Compliance
HQTS assists clients in navigating the e-Filing transition by providing practical guidance on preparing and managing certificate data for electronic submission. This support extends beyond e-Filing mechanics to include broader CPSIA compliance services such as product testing, certification support, documentation review, and regulatory consulting.
By helping clients align their compliance documentation with both CPSC requirements and operational realities, HQTS works to minimize clearance delays, reduce compliance risk, and support long-term regulatory readiness.
Conclusion
The CPSC’s e-Filing requirement represents a fundamental shift in how product safety compliance information is submitted and evaluated for imported consumer goods. While it introduces new procedural responsibilities, it also creates an opportunity for companies to strengthen compliance processes and improve supply-chain transparency.
Organizations that begin preparing now will be better positioned to meet the new requirements and maintain smooth access to the U.S. market. With experienced partners such as HQTS, businesses can approach this transition with confidence and turn regulatory change into a strategic advantage.
