July 8 has passed, and the U.S. CPSC’s new eFiling regulations have officially taken effect. However, many sellers have noticed a counterintuitive phenomenon: shipments are clearing customs as usual, with no automatic intercepts or detention notices. As a result, some are saying, ”It’s all talk and no action,” and ”Let’s wait and see.”

That's a dangerous assumption.

CBP has indeed not yet activated the system’s automatic interception feature—but compliance standards have not been relaxed in the slightest, and undeclared goods are being flagged by the system as ”missing data,” making them significantly more likely to be selected for inspection than declared goods. This is not a ”pass,” but rather a transition period during which ”the consequences will be dealt with later.”

This article breaks down three key issues: what exactly CPSC eFiling entails, the actual logic behind CBP’s ”temporary suspension of detention,” and what cross-border sellers should do now.

I. CPSC eFiling: From ”Post-Market Sampling” to ”Pre-Market Approval”

The CPSC (U.S. Consumer Product Safety Commission), in collaboration with CBP (U.S. Customs and Border Protection), issued the final rule for 16 CFR Part 1110 in January 2025. The key change is contained in just one sentence:It used to be, ”You only submit the certificate if you’re selected in a random check,” but now, ”You must electronically submit the certificate data to the customs system before clearance.”

Scope of Coverage: Approximately 600 HS codes and over 15,000 consumer products. Children’s toys, maternity and baby products, small appliances, furniture, products containing button batteries, and bicycle helmets—virtually all high-frequency categories in cross-border e-commerce are included.

II. 7 Key Data Points + 2 Filing Methods

7 Required Fields

Regardless of which declaration method you choose, the following seven pieces of information are all required and must match your CPC/GCC certificate, test report, and e-commerce platform listing information.identical::

① Product Identifier—Model/SKU/UPC/GTIN, etc. (7 formats available). Common pitfalls: Mixing SKUs across multiple platforms without a unified labeling standard.

② Statute Citation Codes—All CPSC regulations and standard numbers applicable to the product. Common pitfall: Filling in only some of the standards and omitting other regulations that actually apply to the product.

③ Date of Manufacture—Specify the exact year and month. Common pitfall: Entering only the year without the month; the customs clearance system will not accept vague dates.

④ Production Location—Full name of the factory + complete address + contact information. Common pitfalls: Entering only the city name and omitting the full factory address and phone number.

⑤ Product Test Date—The specific date of the most recent compliance test. Common pitfalls: The certificate has expired, and third-party test reports have not been updated in a timely manner.

⑥ Testing Laboratory—Full name and number of the CPSC-accredited laboratory. Common pitfall: If you commission a testing agency that is not CPSC-accredited, customs will not accept the test report.

⑦Contact Information— Names and contact information of contacts in the United States. Common pitfall: Only having information for the Chinese business contact and lacking the information for the authorized contact in the United States.

2 Ways to File

The CPSC offers two options:Full PGA (Full Declaration)respond in singingReference PGA (Citation Declaration)The

1. Full PGA

Suitable for sellers with a limited product range and low shipping frequency. The process is as follows: Each time goods clear customs, the seller provides all seven data points to the customs broker, who then manually enters them one by one into the ACE system. The advantage is that it’s quick to get started and requires no prior registration; the disadvantage is that data must be re-entered each time, which increases the risk of errors and makes this method uneconomical for frequent shipments.

2. Reference PGA

Suitable for established sellers with a wide range of products who frequently export similar items. The process is as follows: Register in advance with the CPSC Product Registry system to obtain three sets of codes—Certifier ID, Product ID, and Version ID. Subsequently, each time you clear customs, you only need to submit these three IDs, and the system will automatically link all certification information. With a one-time registration and long-term reuse, the risk of errors is low, making this the long-term solution officially recommended by the CPSC.

One-Sentence Advice: For SKUs with fewer than 10 items that are shipped only occasionally, use Full PGA to get the process up and running first; for SKUs with more than 10 items and an average of 3 shipments per month or more, register for Product Registry as soon as possible and use Reference PGA.

III. The Real Logic Behind CBP’s ”Temporary Suspension of Interceptions”

After the new regulations took effect on July 8, the enforcement plan released by CBP was ”more lenient” than expected: the system did not enable automatic interception, customs declarations lacking CPSC electronic data will not be automatically rejected, and HTS codes marked with CP1/CP2 can still be declared directly.

However, this does not mean that ”you do not have to file a return.”

Why the postponement?

The reason is quite simple:The volume of goods is too large. CPSC-regulated products cover approximately 600 HS codes. If the system were to immediately block all undeclared goods, a large number of containers would pile up at ports, disrupting the entire supply chain. CBP has chosen to grant the industry a transition period to avoid the chaos that would result from immediate enforcement.

Three Risks Associated with the Grace Period

First, identify the risks. 

Undeclared goods are currently being flagged by the CBP system as ”missing compliance data.” While they appear to have cleared customs, in the system’s backend records, your shipment has been placed on a ”data anomaly” list. Flagged shipments are more likely to be selected for manual spot checks and system risk assessments, and are significantly more likely to be inspected than shipments that have been fully declared.

Second, traceability risks. 

Compliance documents (CPC/GCC certificates, test reports) must be retained for five years, and CBP may audit your import records from the past five years at any time. If a large volume of goods passes through customs today with ”no declaration,” and CBP conducts a retroactive audit of all such shipments in the future, you will face a bulk penalty if you are unable to produce the corresponding certificates for that shipment.

Third, the standards have not been relaxed. 

”The validity requirements for CPC/GCC certificates, the qualifications for CPSC-accredited laboratories, and product testing standards—none of these have been relaxed. The only thing that has been suspended is the button that triggers the system’s automatic blocking; the compliance thresholds remain exactly the same.”

Key Point: CBP has suspended system-based interception, not compliance requirements.

The testing standards haven’t changed, the certification requirements haven’t changed, and the record-keeping obligations haven’t changed. This transition period isn’t meant for you to ”wait a little longer”; rather, it’s a window of opportunity for you to ”get moving.”

Cost of Noncompliance

Once CBP transitions from ”flagging” to ”substantive enforcement,” the consequences are progressive:

Detention of Goods—Demurrage fees range from $100 to $500 per day; every extra day a container stays at the port costs money;

Customs Clearance Delay—Errors or omissions in the information reported lead to manifest discrepancies, causing customs clearance times to stretch from a few hours to 2 to 10 days, and resulting in stockouts during peak season;

Civil Fines—The maximum penalty for false declarations is approximately $120,500 per case; this is calculated not by the number of invoices, but by the number of batches in which issues were discovered;

Return—If CBP denies entry to your shipment, you will be responsible for the shipping costs, and the return record will affect your future customs clearance credibility;

Recall——Products already listed on Amazon and TikTok Shop may face mandatory removal or even recall if the CPSC later determines that they lack the required certification.

IV. 5-Step Action List

Step 1: Self-Assessment of Product Classification. 

Use the Regulatory Robot tool on the CPSC website to check each SKU individually and confirm whether your product falls within the 600 HS codes regulated by the CPSC. This is especially true for toys, baby and maternity products, small appliances, battery-powered products, and furniture—almost all products in these five categories are covered. If you’re unsure, err on the side of caution regarding regulatory coverage.

Step 2: Certificate Verification and Update. 

Check each item to verify whether the CPC/GCC certificate has expired, whether the product model on the certificate matches the current shipping SKU, and whether the laboratory that issued the test report is on the CPSC’s official ”Accepted” list. If any one of these three conditions is not met, the certificate is invalid.

Step 3: Data Standardization. 

Standardize product models, SKU codes, and UPC codes across all platforms to ensure that product identification information on CPC certificates, third-party test reports, and listings on platforms such as Amazon and TikTok Shop is completely consistent across all three sources. Even a single inconsistency will cause the system comparison to fail.

Step 4: Select a filing method. 

Established sellers who ship frequently over the long term should register for Product Registry and use the Reference PGA as soon as possible—a one-time registration for long-term use. Sellers with few SKUs who ship only occasionally should use the Full PGA to get the process up and running first. The former is the long-term solution officially recommended by the CPSC.

Step 5: Coordinate with the customs broker. 

Make sure your customs broker has activated CPSC eFiling permissions in the ACE system and has completed at least one test declaration. Don’t wait until your shipment has arrived at the port and the shipping schedule is tight to discover that your customs broker lacks the necessary permissions—that’s the most costly time window.

If you have any needs, please feel free to contact Qicaiying, and we will tailor a solution just for you:Cell phone: 18676749275 ｜ WeChat: qcygscszk

V. This Is Not an Isolated New Rule

CPSC eFiling is not an isolated product compliance issue. When viewed within the broader context of the U.S. tightening its regulations on cross-border e-commerce in 2026, there isFive Fronts Are Tightening Simultaneously::

Product Approval线——CPSC eFiling (effective July 8), which shifts from ”post-submission spot checks” to ”pre-submission electronic filing,” has the highest threshold and the broadest scope.

Tax Breakthrough透线—FinCEN’s BOI reporting requirements have been comprehensively updated, shifting the focus from shareholding percentages to actual control and tracing ownership all the way to the ultimate beneficial owner.

Platform data线—The IRS has lowered the threshold for 1099-K reporting to $600, and e-commerce platforms are now systematically submitting payment data to the IRS system, so the tax authorities can see every single one of your income transactions.

Bank Compliance线——Major banks such as Chase and Bank of America are tightening their screening processes for non-resident corporate account openings; some are outright rejecting applications, and funding channels are narrowing.

Tariff ChannelsLine——The T86 small-value exemption channel has been permanently shut down, marking the official end of the low-cost direct shipping model; all goods will now be subject to standard customs duties.

Five trends point in the same direction: By 2026, the United States will tighten regulations simultaneously across four areas—products, taxation, capital, and banking—and compliance costs for cross-border e-commerce are rising systematically.

CPSC eFiling is one of the earliest and most widely adopted systems. If a product fails to clear this market access hurdle, there’s no way to proceed with subsequent steps such as opening a bank account and ensuring tax compliance.

VI. 4 Frequently Asked Questions

Q1: I’m sending a sample of my product worth only a few hundred dollars to a customer in the U.S. Do I still need to declare it?

Yes. The new regulations specify that small packages, samples, and gifts valued at less than $800 will all be treated equally, with no exemptions.

Q2: Can test reports from Chinese laboratories be used?

They can be used, but only if they are accredited laboratories listed on the CPSC website with an ”Accepted” status. Not all domestic laboratories meet this requirement, so each one must be verified individually.

Q3: Since customs clearance is possible even without filing a declaration right now, should I wait a little longer?

Not recommended. The larger the volume of deferred futures, the more records will be flagged as ”missing data,” and the greater the risk of retroactive scrutiny in the future. We recommend completing registration and test reporting during the transition period and taking advantage of the error-tolerance mechanism during the voluntary phase to ensure the process runs smoothly.

Q4: We are a trading company and do not manufacture products. Who is responsible for filing the declaration?

The Importer of Record is responsible. If you use a U.S. company as the importer for customs clearance, the responsibility for filing the declaration lies with you. If the supplier or freight forwarder handles customs clearance on your behalf, the contract must clearly define who is responsible for filing the declaration and who bears the associated costs.

put at the end

The essence of CPSC eFiling is to transform the ”certificate of compliance” from a paper document into a data stream that can be automatically verified within the customs system. In the past, you could scramble to find a certificate at the last minute to meet requirements before a container was randomly selected for inspection; now, the system completes the verification before the goods even arrive at the port—if there is a data discrepancy, the shipment is immediately flagged for priority inspection.

CBP has suspended the system-based interception mechanism, not the compliance standards. The transition period is the best opportunity to prepare, not the best reason to wait and see.

If your product falls under the jurisdiction of the U.S. CPSC, here’s what Qicaiying can do for you:

• Self-Assessment and Classification of Products Subject to CPSC Regulation
• Verification of CPC/GCC Certificate Validity
• Setting Up a Compliance Framework for U.S. Importers (U.S. Company Registration + EIN + BOI Filing)
• Product Registry Registration and Filing Guidelines
• Assistance with Integrating eFiling Permissions for Customs Brokers
• End-to-End Diagnosis of Cross-Border Tax and Financial Compliance

CPSC eFiling is a matter of product market access, but behind that lies the question of whether the entire U.S. compliance framework is in place. From company registration to tax compliance to opening a bank account, every step requires advance planning.

Contact Qi Cai Ying to undergo a comprehensive assessment of your U.S. compliance structure.Cell phone: 18676749275 ｜ WeChat: qcygscszk

Enterprise Finance Group

Founded in 2015 and headquartered in Shenzhen, Qicaiying Group is a leading provider of corporate services and tax compliance solutions in China.

The Group is deeply committed to providing services across the entire corporate lifecycle. Its core business areas include: business registration, bookkeeping services, tax compliance, overseas company registration (Hong Kong, the U.S., Singapore, Mexico, etc.), cross-border structuring, outbound direct investment (ODI) filing, overseas tax planning, bank account opening assistance, and identity planning.

Over the past decade, Qicaiying has served more than 10,000 corporate clients and has accumulated solid practical experience in key areas such as corporate structuring in Hong Kong and overseas, cross-border tax and financial compliance, and corporate accounting management. The Group boasts a team of seasoned financial and tax advisors who closely monitor changes in domestic and international tax systems and regulatory trends, providing clients with one-stop solutions ranging from structural planning to implementation.