Companies importing consumer products into the United States now face a significant compliance change. As our colleagues on Product Perspective explain, effective July 8, the U.S. Consumer Product Safety Commission’s (CPSC) new eFiling requirement requires importers to electronically submit product safety certificate information at the time of entry.
While the rule does not create new product testing or certification obligations, it fundamentally changes how Certificate of Compliance information is provided to regulators. Instead of maintaining certificates and producing them only when requested, importers must now submit required certificate data electronically through U.S. Customs and Border Protection’s Automated Commercial Environment (ACE) as part of the entry process.
The rule applies broadly to consumer products subject to CPSC regulations, standards, bans, or other requirements. Importantly, there is no de minimis exemption, meaning affected shipments require certificate information regardless of value. The change has implications not only for importers, but also for manufacturers, suppliers, customs brokers, and compliance teams that support the movement of regulated products through the supply chain.
To comply with the new requirement, importers may either submit complete certificate data with each entry or preload certificate information into the agency’s Product Registry and provide reference identifiers for future shipments. The Product Registry option may be particularly valuable for businesses that repeatedly import the same products, reducing the need to resubmit the same certificate information for every shipment.
Key Dates
| Effective Date | Scope |
| July 8, 2026 | Most imported consumer products subject to CPSC certification requirements |
| January 8, 2027 | Consumer products imported into a Foreign Trade Zone and subsequently entered for consumption or warehousing |
Although the CPSC has indicated it does not currently intend to seek denial of entry solely for missing certificate data, the agency will continue enforcing certificate requirements and may pursue action against non-compliant products, including seizures and penalties.
For supply chain stakeholders, the new framework underscores the importance of accurate product data, strong compliance controls, and effective coordination among importers, suppliers, and customs brokers. Companies that import consumer products should review their product portfolios, confirm which items are subject to CPSC certification requirements, evaluate existing compliance documentation, and establish processes for providing certificate data before shipments arrive at the border.
Please contact your Husch Blackwell attorney should you have specific questions or concerns.