ComplyMyImport guide
CPSC eFiling is in effect: what importers need to know
For most imported consumer products that require a CPSC certificate, certificate data must now be filed electronically with US Customs and Border Protection. The requirement took effect July 8, 2026. A later January 8, 2027 date applies to covered products entered for consumption or warehousing from a Foreign Trade Zone.
For a small importer, the real change is operational: compliance information has to be ready when the entry is filed. A test report sitting in a supplier's inbox is not a filing process, and a customs broker cannot determine which safety rules apply to a product on the importer's behalf.
The border deadline starts with the product record
The most reliable eFiling workflow begins before a shipment is booked. Each product record should connect the finished-product identifier to the responsible importer, manufacturing facility, applicable CPSC rules, test evidence, testing laboratory, and records contact.
That matters especially for children's toys and accessories. A single item may involve ASTM F963 requirements, lead limits, phthalates restrictions, small-parts rules, or tracking-label obligations. Applicability depends on the product's design, materials, age grading, and other facts. Those conclusions should be made through a documented, reviewable process—not guessed from an HTS code or copied from a similar SKU.
The seven certificate data elements
CPSC's eFiling materials identify seven categories of certificate information:
- Product ID for the finished product
- Citation codes for each applicable consumer product safety rule
- Date of manufacture
- Place of manufacture and manufacturing-party details
- Date the finished product was most recently tested for compliance
- Testing-laboratory details
- Contact information for the person maintaining test records
These are structured data fields, but their quality depends on the evidence behind them. Before preparing a filing, confirm that model numbers match across reports and product records, factory details are complete, test dates remain relevant, and each cited rule has appropriate support.
Choose the filing path with your broker
There are two primary ways to provide certificate data in the CPSC Partner Government Agency Message Set.
Full PGA Message Set
The broker or other authorized filer transmits all seven certificate data elements through CBP's Automated Commercial Environment, or ACE. This path may be practical for importers with a small number of regulated products or products that are not imported repeatedly.
Reference PGA Message Set
The importer first stores certified product data in the CPSC Product Registry. The broker then transmits three Certificate Identifiers—Certifier ID, Product ID, and Version ID—through ACE. This path can reduce repeated data entry when the same product is imported more than once and the underlying certificate information remains valid.
The Product Registry does not send an entry filing to ACE. Registry storage, the broker's PGA transmission, and the ACE response are separate events and should be tracked separately.
A ComplyMyImport operating playbook
ComplyMyImport is designed to help small importers turn scattered compliance documents into a controlled product workflow.
1. Build the evidence record
Collect current test reports, supplier and factory details, product specifications, label artwork, and existing certificates. Keep the evidence connected to the correct product and variant instead of relying on folders named only by shipment or supplier.
2. Resolve gaps before entry
Compare the product facts with versioned CPSC rules. Flag missing, inconsistent, or expired evidence for review. AI-assisted extraction can help locate data in a report, but it is not a legal determination and should not decide product applicability or approve a certificate.
3. Prepare the certificate for approval
Assemble a CPC or GCC draft from reviewed evidence. An authorized customer representative must verify and approve the certificate; ComplyMyImport does not automatically issue or approve it.
4. Create a broker-ready handoff
For a Full PGA filing, provide the reviewed certificate fields in a structured package. For a Reference filing, provide the exact Certifier ID, Product ID, and Version ID associated with the approved product record. Include shipment and entry-line mapping so the broker knows which data belongs to each item.
5. Reconcile the result
Record when the package was sent, who received it, what the broker transmitted, and whether an ACE response or correction followed. Do not treat a generated export or Product Registry record as proof that CBP accepted the entry.
Common failure points to fix now
- Supplier and test-report model numbers do not match the commercial SKU
- The manufacturing location is incomplete or identifies only the supplier
- A certificate lists citations without evidence supporting each one
- Product changes are made without reviewing whether retesting or a new certificate version is needed
- Registry identifiers are reused after the underlying product or certificate data changes
- No one owns the final broker handoff or exception response
These are data-governance problems more than filing-screen problems. Solving them upstream makes the entry process easier to manage and creates a clearer record if a filing is questioned later.
Start with one product
Do not wait for a full catalog cleanup to test the workflow. Choose one repeatedly imported product, assemble its evidence, validate the certificate fields, decide the filing path with your broker, and document the handoff. The ComplyMyImport readiness check can help identify the first gaps before you create a managed product workspace.
ComplyMyImport supports evidence organization, deterministic requirement mapping, human-controlled certificate preparation, and broker-ready eFiling data. It is not a law firm, customs broker, testing laboratory, or importer of record. This page provides general educational information, not legal or customs advice. Confirm requirements for your products with CPSC, CBP, your customs broker, and qualified counsel.
Official resources
- CPSC eFiling overview and FAQs: cpsc.gov/eFiling
- CPSC eFiling Document Library: cpsc.gov/eFiling-Document-Library
- Federal Register final rule, Certificates of Compliance: federalregister.gov/d/2024-30826
- CBP Automated Commercial Environment: cbp.gov/trade/automated/how-to-use-ace