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, \u201dYou only submit the certificate if you\u2019re selected in a random check,\u201d but now, \u201dYou must electronically submit the certificate data to the customs system before clearance.\u201d<\/strong><\/p>\n\n\n\n Scope of Coverage: Approximately 600 HS codes and over 15,000 consumer products. Children\u2019s toys, maternity and baby products, small appliances, furniture, products containing button batteries, and bicycle helmets\u2014virtually all high-frequency categories in cross-border e-commerce are included.<\/p>\n\n\n\n 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<\/strong>::<\/p>\n\n\n\n \u2460 Product Identifier<\/strong>\u2014Model\/SKU\/UPC\/GTIN, etc. (7 formats available). Common pitfalls: Mixing SKUs across multiple platforms without a unified labeling standard.<\/p>\n\n\n\n \u2461 Statute Citation Codes<\/strong>\u2014All 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.<\/p>\n\n\n\n \u2462 Date of Manufacture<\/strong>\u2014Specify the exact year and month. Common pitfall: Entering only the year without the month; the customs clearance system will not accept vague dates.<\/p>\n\n\n\n \u2463 Production Location<\/strong>\u2014Full name of the factory + complete address + contact information. Common pitfalls: Entering only the city name and omitting the full factory address and phone number.<\/p>\n\n\n\n \u2464 Product Test Date<\/strong>\u2014The 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.<\/p>\n\n\n\n \u2465 Testing Laboratory<\/strong>\u2014Full 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.<\/p>\n\n\n\n \u2466Contact Information<\/strong>\u2014 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.<\/p>\n\n\n\n The CPSC offers two options:Full PGA (Full Declaration)<\/strong>respond in singingReference PGA (Citation Declaration)<\/strong>The<\/p>\n\n\n\n 1. Full PGA<\/strong><\/p>\n\n\n\n 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\u2019s 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.<\/p>\n\n\n\n 2. Reference PGA<\/strong><\/p>\n\n\n\n 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\u2014Certifier 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.<\/p>\n\n\n\n One-Sentence Advice<\/strong>: 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.<\/p>\n\n\n\n After the new regulations took effect on July 8, the enforcement plan released by CBP was \u201dmore lenient\u201d 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.<\/p>\n\n\n\n However, this does not mean that \u201dyou do not have to file a return.\u201d<\/p>\n\n\n\n The reason is quite simple:The volume of goods is too large.<\/strong> 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.<\/p>\n\n\n\n First, identify the risks.<\/strong> <\/p>\n\n\n\n Undeclared goods are currently being flagged by the CBP system as \u201dmissing compliance data.\u201d While they appear to have cleared customs, in the system\u2019s backend records, your shipment has been placed on a \u201ddata anomaly\u201d 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.<\/p>\n\n\n\n Second, traceability risks.<\/strong> <\/p>\n\n\n\n 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 \u201dno declaration,\u201d 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.<\/p>\n\n\n\n Third, the standards have not been relaxed.<\/strong> <\/p>\n\n\n\n \u201dThe validity requirements for CPC\/GCC certificates, the qualifications for CPSC-accredited laboratories, and product testing standards\u2014none of these have been relaxed. The only thing that has been suspended is the button that triggers the system\u2019s automatic blocking; the compliance thresholds remain exactly the same.\u201d<\/p>\n\n\n\n Key Point: CBP has suspended system-based interception, not compliance requirements.<\/strong><\/p>\n\n\n\n The testing standards haven\u2019t changed, the certification requirements haven\u2019t changed, and the record-keeping obligations haven\u2019t changed. This transition period isn\u2019t meant for you to \u201dwait a little longer\u201d; rather, it\u2019s a window of opportunity for you to \u201dget moving.\u201d<\/p>\n\n\n\n Once CBP transitions from \u201dflagging\u201d to \u201dsubstantive enforcement,\u201d the consequences are progressive:<\/strong><\/p>\n\n\n\n Detention of Goods<\/strong>\u2014Demurrage fees range from $100 to $500 per day; every extra day a container stays at the port costs money;<\/strong><\/p>\n\n\n\n Customs Clearance Delay<\/strong>\u2014Errors 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;<\/strong><\/p>\n\n\n\n Civil Fines<\/strong>\u2014The 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;<\/strong><\/p>\n\n\n\n Return<\/strong>\u2014If 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;<\/strong><\/p>\n\n\n\n Recall<\/strong>\u2014\u2014Products 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.<\/p>\n\n\n\n Step 1: Self-Assessment of Product Classification.<\/strong> <\/p>\n\n\n\n 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\u2014almost all products in these five categories are covered. If you\u2019re unsure, err on the side of caution regarding regulatory coverage.<\/p>\n\n\n\n Step 2: Certificate Verification and Update.<\/strong> <\/p>\n\n\n\n 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\u2019s official \u201dAccepted\u201d list. If any one of these three conditions is not met, the certificate is invalid.<\/p>\n\n\n\n Step 3: Data Standardization.<\/strong> <\/p>\n\n\n\n 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.<\/p>\n\n\n\n Step 4: Select a filing method.<\/strong> <\/p>\n\n\n\n Established sellers who ship frequently over the long term should register for Product Registry and use the Reference PGA as soon as possible\u2014a 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.<\/p>\n\n\n\n Step 5: Coordinate with the customs broker.<\/strong> <\/p>\n\n\n\n Make sure your customs broker has activated CPSC eFiling permissions in the ACE system and has completed at least one test declaration. Don\u2019t 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\u2014that\u2019s the most costly time window.<\/p>\n\n\n\n If you have any needs, please feel free to contact Qicaiying, and we will tailor a solution just for you:Cell phone: 18676749275<\/strong> \uff5c WeChat: qcygscszk<\/strong><\/strong><\/p>\n\n\n\n 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<\/strong>::<\/p>\n\n\n\n Product Approval<\/strong>\u7ebf<\/strong>\u2014\u2014CPSC eFiling (effective July 8), which shifts from \u201dpost-submission spot checks\u201d to \u201dpre-submission electronic filing,\u201d has the highest threshold and the broadest scope.<\/p>\n\n\n\n Tax Breakthrough<\/strong>\u900f<\/strong>\u7ebf<\/strong>\u2014FinCEN\u2019s 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.<\/p>\n\n\n\n Platform data<\/strong>\u7ebf<\/strong>\u2014The 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.<\/p>\n\n\n\n Bank Compliance<\/strong>\u7ebf<\/strong>\u2014\u2014Major 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.<\/p>\n\n\n\n Tariff Channels<\/strong>Line\u2014<\/strong>\u2014The 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.<\/p>\n\n\n\n Five trends point in the same direction: By 2026, the United States will tighten regulations simultaneously across four areas\u2014products, taxation, capital, and banking\u2014and compliance costs for cross-border e-commerce are rising systematically.<\/strong><\/p>\n\n\n\n CPSC eFiling is one of the earliest and most widely adopted systems. If a product fails to clear this market access hurdle, there\u2019s no way to proceed with subsequent steps such as opening a bank account and ensuring tax compliance.<\/p>\n\n\n\n Q1: I\u2019m 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?<\/strong><\/p>\n\n\n\n Yes. The new regulations specify that small packages, samples, and gifts valued at less than $800 will all be treated equally, with no exemptions.<\/p>\n\n\n\n Q2: Can test reports from Chinese laboratories be used?<\/strong><\/p>\n\n\n\n They can be used, but only if they are accredited laboratories listed on the CPSC website with an \u201dAccepted\u201d status. Not all domestic laboratories meet this requirement, so each one must be verified individually.<\/p>\n\n\n\n Q3: Since customs clearance is possible even without filing a declaration right now, should I wait a little longer?<\/strong><\/p>\n\n\n\n Not recommended. The larger the volume of deferred futures, the more records will be flagged as \u201dmissing data,\u201d 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.<\/p>\n\n\n\n Q4: We are a trading company and do not manufacture products. Who is responsible for filing the declaration?<\/strong><\/p>\n\n\n\n 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.<\/p>\n\n\n\n The essence of CPSC eFiling is to transform the \u201dcertificate of compliance\u201d 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\u2014if there is a data discrepancy, the shipment is immediately flagged for priority inspection.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n If your product falls under the jurisdiction of the U.S. CPSC, here\u2019s what Qicaiying can do for you:<\/strong><\/p>\n\n\n\n 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.<\/p>\n\n\n\n Contact Qi Cai Ying to undergo a comprehensive assessment of your U.S. compliance structure.Cell phone: 18676749275<\/strong> \uff5c WeChat: qcygscszk<\/strong><\/strong><\/p>\n\n\n\n Founded in 2015 and headquartered in Shenzhen, Qicaiying Group is a leading provider of corporate services and tax compliance solutions in China.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n 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.<\/p>","protected":false},"excerpt":{"rendered":" July 8 has passed, and the U.S. CPSC\u2019s 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, \u201dIt\u2019s all talk and no action,\u201d and \u201dLet\u2019s wait and see.\u201d<\/p>\n That's a dangerous assumption.<\/p>\n CBP has indeed not yet activated the system\u2019s automatic interception feature\u2014but compliance standards have not been relaxed in the slightest, and undeclared goods are being flagged by the system as \u201dmissing data,\u201d making them significantly more likely to be selected for inspection than declared goods. This is not a \u201dpass,\u201d but rather a transition period during which \u201dthe consequences will be dealt with later.\u201d<\/p>\n This article breaks down three key issues: what exactly CPSC eFiling entails, the actual logic behind CBP\u2019s \u201dtemporary suspension of detention,\u201d and what cross-border sellers should do now.<\/p>","protected":false},"author":10,"featured_media":9745,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_yoast_wpseo_focuskw":"7\u67088\u65e5\u7f8e\u56fdCPSC\u7535\u5b50\u7533\u62a5\u6b63\u5f0f\u65bd\u884c","_yoast_wpseo_title":"","_yoast_wpseo_metadesc":"","_yoast_wpseo_opengraph-title":"","_yoast_wpseo_opengraph-description":"","footnotes":""},"categories":[17,18,15,13],"tags":[1562,535],"class_list":["post-11961","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-allguide","category-recomguide","category-industry","category-guide","tag-cpsc","tag-535"],"yoast_head":"\ndimension (math.)<\/strong><\/td> old rules<\/strong><\/td> 2026 New Regulations<\/strong><\/td><\/tr> Submission Methods<\/td> Paper certificates are included with the shipment or available for review<\/td> Submissions must be made electronically through the ACE system.<\/td><\/tr> Audit Date<\/td> Post-event spot checks<\/td> Automatic System Verification Before Customs Clearance<\/td><\/tr> Coverage<\/td> Randomly inspect a sample of the goods<\/td> All Products Regulated by the CPSC<\/td><\/tr> Small Package\/Sample<\/td> No credit check required for amounts under $800<\/td> No Exceptions, Equal Treatment for All<\/strong><\/td><\/tr> Document Retention<\/td> Recommendation: Retain<\/td> Mandatory retention for 5 years<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n II. 7 Key Data Points + 2 Filing Methods<\/strong><\/h2>\n\n\n\n
7 Required Fields<\/strong><\/h3>\n\n\n\n
2 Ways to File<\/strong><\/h3>\n\n\n\n
III. The Real Logic Behind CBP\u2019s \u201dTemporary Suspension of Interceptions\u201d<\/strong><\/h2>\n\n\n\n
Why the postponement?<\/strong><\/h3>\n\n\n\n
Three Risks Associated with the Grace Period<\/strong><\/h3>\n\n\n\n
Cost of Noncompliance<\/strong><\/h3>\n\n\n\n
IV. 5-Step Action List<\/strong><\/h2>\n\n\n\n
![\"\u6b64\u56fe\u7247\u7684](\"https:\/\/qcyboss.oss-cn-shenzhen.aliyuncs.com\/wp-content\/uploads\/2026\/03\/20260323160847384.jpg\")
<\/figure>\n\n\n\nV. This Is Not an Isolated New Rule<\/strong><\/h2>\n\n\n\n
VI. 4 Frequently Asked Questions<\/strong><\/h2>\n\n\n\n
put at the end<\/strong><\/h2>\n\n\n\n
\n
<\/figure>\n\n\n\nEnterprise Finance Group<\/strong><\/h2>\n\n\n\n