Last verified August 6, 2026

Importers now eFile certificates of compliance with CBP

This is not a proposal or a pilot. Since 8 July 2026, importers of most regulated consumer products file their certificate data electronically with CBP at entry.

Certificates of compliance used to travel with the shipment as a document — something you produced if asked. From 8 July 2026, importers of most regulated consumer products file the certificate data electronically with CBP, through a Partner Government Agency Message Set submitted at entry.

The practical shift is when the data has to be right. A PDF in a folder can be corrected after the fact. A data element transmitted at entry either matches the shipment or it does not, and it is evaluated at the point the goods arrive.

One qualifier that most summaries of this rule drop: the Final Rule carries two dates, and since September 2025 they are two different kinds of date. As published in January 2025 the rule stated two effective dates. The Commission corrected that in (90 FR 45917, 24 September 2025), because the Office of the Federal Register requires a rule to carry one effective date: the rule is now effective 8 July 2026, with two applicability dates. It is applicable 8 July 2026 for regulated consumer products generally, and 8 January 2027 for products entered from a foreign trade zone for consumption or warehousing. The Commission was explicit that this “has no substantive effect on the dates by which products subject to the final rule must be in compliance” — so if you clear goods out of an FTZ, 8 January 2027 is still the date that governs your entries. Only the label changed.

CPC or GCC — they are not interchangeable

Both are certificates of compliance, and which one you owe is determined by the product, not by preference.

	Children’s Product Certificate (CPC)	General Certificate of Conformity (GCC)
Applies to	Products designed or intended primarily for children 12 and under	General-use consumer products
Third-party testing	Mandatory, at a CPSC-accepted laboratory	Not always required — but compliance must still be certified
Based on	Passing results from the accepted lab	A reasonable testing program

The most common misreading is treating the GCC as a lighter CPC for the same goods. It is not a lower tier of the same thing — it applies to a different category. If the product is intended for children 12 and under, third-party testing at an accepted lab is not optional, and no GCC substitutes for it.

The certificate is yours, not your supplier’s

The obligation sits with the domestic manufacturer, or with the importer for imported goods. A test report from the factory is an input to your certificate; it is not your certificate, and a supplier’s certificate naming the supplier does not discharge your duty.

This is the single most expensive assumption in the whole area, and eFile makes it more expensive rather than less — because the party transmitting the data at entry is you. The statutory reason, and the parties who cannot issue it on your behalf, are set out in who can issue a Children’s Product Certificate for your SKU.

If you sell the same goods on a marketplace, that certificate has a second reader. 15 U.S.C. 2063(g)(3) entitles every distributor or retailer to a copy, so the document a platform asks you to upload is the same one you certify at entry — Amazon sellers and the Children’s Product Certificate covers where that request comes from.

Which rules actually apply to your SKU

“Which CPSC rules apply” is a per-SKU question, not a per-category one. Two items that sit in the same catalogue line can attract different rules on the basis of a material, a coating, a magnet, a battery, or the age range on the packaging. Certifying against the category is how a SKU ends up under-tested.

It is also not preparatory work. 16 CFR 1110.11(a)(2) makes the rule list an element of the certificate itself — it must identify separately all applicable rules, bans, standards or regulations. CPSC scope determination covers why that step has to be finished before a laboratory can even be chosen.

Working it out means answering, for the specific item:

Is it designed or intended primarily for children 12 and under?
Which product-specific safety rules attach — and on what basis?
Do any component-level requirements apply independently of the finished good?
Which of those require third-party testing at an accepted lab?

That last question is also the one that decides the bill, because testing is quoted per rule rather than per certificate. What a Children’s Product Certificate costs to get prepared separates the parts of the cost that are fixed from the parts that move with scope, and covers the small batch route at 15 U.S.C. 2063(d)(4).

Where CertScope fits

CertScope determines which CPSC rules apply to a specific SKU, shows the basis for each rule it applies so the determination can be checked, and builds the corresponding certificate. We prepare; you sign and file — CertScope does not sign or file on anyone’s behalf.

Pricing is one-time with no subscription: $29 for a single SKU, $99 for up to 10, $249 for up to 40. See how a determination is made, or contact us to reach a person.

Verified on 4 September 2026 against the Final Rule at 90 FR 1800 and the Consumer Product Safety Act as codified at 15 U.S.C. 2052 and 2063. Nothing here is legal advice.