CPSC eFiling Requirements Checklist

A certificate that names the wrong SKU wastes the broker handoff and can leave rejected certificate data on an entry ACE already accepted. This CPSC eFiling requirements checklist records the seven certificate data elements from the supplier file and what the broker received. Wholesale Sourced is an independent publisher, and the tables below are the checklist to copy.

Record seven Full PGA certificate data elements for one SKU, or three Reference identifiers from the Product Registry, and leave a cell blank when the file does not print it. The CPSC eFiling FAQ fetched October 18, 2026 lists the Full set as Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact. The same page lists the Reference set as Certifier ID, Product ID, and Version ID, and it says the Product Registry does not communicate with ACE. The eCFR text of 16 CFR 1110.13(a), fetched the same day, says each finished product certificate must describe only one product. CBP CSMS #69382435, bulletin July 29, 2026, says ACE can accept an entry that is missing CPSC data, and that CPSC can still reject that data. The filled rows later on this page are hypothetical.

Copy the handoff sheet

Use one row per data element, and repeat the seven rows for each SKU. Write a value only when the source file prints it. An empty value cell means that file did not show the element. Do not fill it from memory, from a carton count, or from a different SKU’s certificate.

The FAQ uses seven for two different lists. A Full PGA Message Set asks the importer to give the broker seven required product certificate data elements: Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact. A separate answer says the Product ID must be one of seven alphanumeric types: GTIN, SKU, UPC, Model Number, Serial Number, Registered Number, or Alternate ID. Alternate ID is for an identifier the other six types do not cover, and that field still holds only the product identifier. Section 1110.11(a)(1) lists the same seven types, using the words stock keeping number for SKU and alternate identifier for Alternate ID, and it also asks for a sufficient description to match the finished product to the certificate. Lot number, model style, and model color can sit with that description. They are not a substitute for the Product ID type.

Rule of thumb. If the certificate prints an identifier for one product and the purchase order lists a second SKU, leave the second SKU’s seven value cells blank. Section 1110.13(a) says each finished product certificate must describe only one product. Copying the first identifier onto the second row is the failure mode this sheet is built to prevent.

The header and the blank rows are the record to copy. The filled tables later on this page are a hypothetical file. Delete those filled rows before you use the sheet on a real order.

Section 1110.11 splits several of those seven labels into address lines. Copy only the lines the file prints.

Manufacture Date, under section 1110.11(a)(5), is month and year at a minimum. For a manufacturing run over a series of days, the certificate gives the initial date of manufacture. If the file prints a full date, copy the full date. If it prints a year and no month, the cell stays unfinished. Do not invent the month.

Manufacture Place, under the same paragraph, includes a manufacturer name, street address, city, state or province, country or administrative region, email address, and telephone number. Section 1110.11(a)(6) asks for the most recent date of testing and the place or places of that testing. Put the date on the Product Test Date row. Put each laboratory’s name, street address, city, state or province, country or administrative region, email address, and telephone number on the Testing Laboratory row. Point of Contact is one FAQ label. Section 1110.11(a)(3) asks for the certifier, and section 1110.11(a)(4) asks for the individual who maintains the records. A position title can stand for that individual when the position is always staffed and responsive to CPSC’s requests. If the file names only one of those people, write that person on the Point of Contact row. Leave the header’s party-responsible cell blank when the file does not also name the certifier. Do not merge two people into one cell.

An eFiled finished product certificate must be in English, under section 1110.9(a). The Cornell text of 15 USC 2063(g)(2), fetched October 18, 2026, says every certificate required under that section must have its required content in English, and that the certificate may also carry the same content in another language. Copy the English lines. If an element has no English line on the file, leave the cell blank. Do not translate it from memory.

The CPSC importers page, fetched the same day, says that for eFiling the importer is the importer of record eligible to make entry for imported finished products under the Tariff Act of 1930. That party may be an owner, a purchaser, or an authorized customs broker. If a broker who is authorized to make entry does not have sufficient knowledge of the products to be held responsible for testing and certification, the broker may identify the owner, purchaser, or consignee who authorized the entry as the party responsible for the CPSC certificate requirements. Write that name only when a paper shows it. The same page says the importer is typically the entity that creates the Product Registry business account. If that account is for an importer of record, the party should provide the IOR number assigned by CBP when creating the account. If the certifying party is an owner, purchaser, or consignee who is not the importer of record, that party does not need to provide an IOR number. This page does not describe what that number looks like. Section 1110.3 points at 19 USC 1484(a)(2)(B) for the same importer-of-record role. The DDP importer of record checklist is where the filer’s name is written. A DDP label does not fill the party-responsible cell on this page.

Before you copy a supplier name into “who provided the file,” match the legal name on the guide to checking a Chinese supplier’s legal name. That guide does not fill a certificate element.

Read a hypothetical file

Every identifier below is made up. Westline Ceramics, Maple Goods, HC-14, and LAB-09 are not real firms or real files. The dates are dates printed on those made-up files. They are not CPSC effective dates. Do not copy them onto a live order.

Worked example. Maple Goods is buying two mug SKUs from Westline Ceramics. The purchase order lists WS-2201 and WS-2208. Westline sends certificate file HC-14. That file prints Product ID type SKU and the ID WS-2201, a manufacture date of 4 March 2026, and a product test date of 18 March 2026. The pages of HC-14 used here do not print citation codes, a manufacture place, a laboratory name, or a point of contact. Those four cells stay blank. Westline also sends lab sheet LAB-09, which prints a product test date of 2 June 2026 and does not print a SKU. Count for WS-2201: three values are printed, four of the seven are blank, and the printed test date is not matched to LAB-09.

The broker receipt column stays empty on every row. The seven elements for WS-2201 are not all on the excerpt, and the test dates disagree, so there is nothing complete to hand over. WS-2208 has no certificate that prints WS-2208. Do not borrow the WS-2201 rows to close that gap.

Read the two stacks as two files, the way HC-14 and LAB-09 are two files. The photograph has no writing on either stack. On the sheet, a later test date does not replace the certificate date until the certificate itself states the most recent test date. The FAQ says a certificate must state the most recent date of testing and identify each laboratory that did testing used to support the certificate, including a component test when that test is part of the affirmation. LAB-09’s June date and HC-14’s March date cannot both be the test date for WS-2201 until one certificate says so. Leave the broker cell blank while they disagree.

The same FAQ says Test URL, Test Report Key, and Test Report ID are optional and encouraged, and that CPSC may ask for supporting test records. This sheet does not add those three names as required rows. The source-file column is where you point at HC-14 or LAB-09. If a testing exclusion is relied upon, the FAQ says a testing exclusion code must be on the certificate. The same FAQ says that as of July 8, 2026 the revised part 1110 requires identification of testing exclusions relied upon. Section 1110.11(c) says the certificate identifies the exclusion in lieu of the test date and place for that regulation, and it still lists the applicable rules under section 1110.11(a)(2). The exclusion row stays blank when no exclusion is relied upon. This page does not print a sample code.

When a product needs this sheet

Start with whether a certificate is required. If you cannot tell, leave the citation row blank and do not treat the shipment as ready for the broker. The FAQ points readers to HTS, citation, and testing-exclusion lists in the CPSC Document Library. It says those lists are not all-encompassing and were guidance for the voluntary stage. CPSC does not notify the trade of HTS updates and tells the trade to check the U.S. International Trade Commission website. This sheet does not classify the product and does not decide a release. Read that FAQ sentence next to the bulletin below: CSMS #69382435 says eFiling of certificate data is mandatory and was fully implemented on July 8, 2026. The FAQ’s “voluntary stage” label on those lists is still on the page fetched October 18, 2026. This article does not turn that label into a new effective date.

The FAQ’s final-rule dates are not one date for every shipment. Requirements for most imported consumer products take effect on July 8th, 2026. Requirements for consumer products imported into a foreign-trade zone and then entered for consumption or warehousing take effect on January 8th, 2027. For that zone withdrawal, the FAQ says certificate data is submitted when the entry is filed, and that ACE can take the CPSC message set on a type 06 consumption entry or as part of a weekly entry. The eCFR page prints its source line as 90 FR 1843, January 8, 2025, unless otherwise noted. That line is the source note on the page. It is not a substitute for the two FAQ dates. Write which of the two FAQ dates you are using only after you know the cargo path. If you do not know it, leave the header’s shipment reference filled and do not guess the date.

A product manufactured in the United States is outside this import handoff. Section 1110.7(b) names the manufacturer, or the private labeler when the product is privately labeled and the manufacturer does not issue the certificate, as the finished product certifier. Section 1110.13(a)(2) says that certificate is issued on or before the date the finished product is distributed in commerce and is available for inspection within 24 hours of a CPSC request. That 24-hour window is an availability rule for a domestic certificate. It is not the import eFile timing in the next section.

A noncommercial shipment from one consumer outside the United States to another consumer in the United States does not need eFiling when it is a gift or a transfer of personal effects, and the sender had physical possession of the product before sending it. A sale, including a sale by one consumer to another through an online marketplace, is commercial. The FAQ says those commercial transactions are outside the exemption. Section 1110.3 says CPSC will not typically consider a consumer purchasing or receiving products for personal use or enjoyment to be the importer responsible for certification. That sentence uses the regulation’s word “typically.” It does not name a person on your shipment. Used products manufactured before the effective date of the applicable CPSC rule do not need a certificate, and eFiling does not add one. Used products manufactured after that date do need a certificate, and eFiling applies when the import is commercial. This page does not list those rule dates.

Goods imported only as samples, and not for distribution into U.S. interstate commerce or use by U.S. consumers, do not need to meet CPSC product safety requirements, according to that FAQ. The importer has to be able to show the samples will not be distributed to or used by consumers. The FAQ says non-compliant samples may not be sold or distributed to U.S. consumers, and it names HTS code 9817.85.01 for prototypes used only for development, testing, product evaluation, or quality control. If that is the shipment, this handoff sheet is the wrong record.

Any product that requires certification still needs an eFiled certificate at any shipment value. The FAQ states there is no Section 321 exemption. It also says a Disclaim PGA Message Set is not required, and it encourages importers to file one because of a possible effect on the risk score. Some noncommercial and pre-rule used entries may use Disclaim A. This sheet does not fill a disclaimer, because the FAQ text read here does not list the fields inside Disclaim A.

For finished products imported by mail, or for which a de minimis duty exemption under 19 USC 1321(a)(2)(C) is claimed, section 1110.3 says the importer for CPSC certificate purposes is a party eligible to make entry under CBP statutes and regulations, and that party may be an owner, purchaser, consignee, or authorized customs broker. This page did not open those CBP statutes. Write the name only when a paper shows it.

Resold and overstock finished products that are subject to a CPSC rule, ban, or standard and are distributed in commerce are inside the certificate and eFiling requirements, on the same FAQ. Do not drop the sheet because the goods are not a first production run.

Full filing and Reference filing

For a Full PGA Message Set, the importer gives the broker the seven data elements, and the broker files them in the CPSC PGA Message Set. The FAQ says the Product Registry is not required for Full filings. You still keep the source file, the buyer check, and the broker receipt on this sheet. Those three notes are not part of the seven elements.

Section 1110.13(a)(1) says the finished product certifier eFiles the section 1110.11 data elements at the time of filing the entry, or at the time of filing the entry and the entry summary if both are filed together. That sentence covers finished products manufactured outside the United States and offered for importation for consumption or warehousing, including a withdrawal from a foreign-trade zone and a product eligible for the de minimis duty exemption under 19 USC 1321(a)(2)(C). The Cornell text of 15 USC 2063(g)(4) says the Commission may, by rule, provide for electronic filing of certificates up to 24 hours before arrival. The timing this page uses is the timing printed in section 1110.13(a)(1), not a 24-hour deadline read out of that statutory “up to.”

For a product manufactured outside the United States and imported by mail, section 1110.13(a)(1) uses a different clock. The certifier must enter the section 1110.11 data elements into the Product Registry before the product arrives in the United States. That is not the same act as handing the broker three Reference identifiers on the day of entry.

For a Reference PGA Message Set, the importer enters the certificate data in the Product Registry first, then gives the broker the Certifier ID, the Product ID, and the Version ID. The FAQ says the Product ID used there is the Primary Product ID, and that the Primary Product ID together with the Version ID is the key for updating a certificate already stored in a Product Collection. The Product Registry does not communicate with ACE. After the registry entry exists, someone still has to give the broker those three identifiers. A Reference message set needs an entry. The FAQ says it cannot be attached to a CBP manifest.

On the hypothetical PO-19, the Reference table stays blank:

HC-14 prints a SKU. It does not print a Certifier ID or a Version ID. Copying WS-2201 into the Reference Product ID cell would pretend the other two identifiers were known. Leave all three blank until the registry shows them. This rewrite did not open a Product Registry screen, so it does not describe registry labels beyond the names in the FAQ and the definition in section 1110.3. That definition calls the Product Registry a CPSC database for the section 1110.11 data elements, and it includes any CPSC successor system.

The FAQ says users can bulk-upload certificate data to the Product Registry with a CSV file or an API. It does not print the CSV column headers in the text fetched for this page. Do not invent those headers on this sheet. Finish the handoff rows first, then use whatever template the registry actually offers.

Section 1110.11(a)(7) says attestations for eFiled certificates are included in the Product Registry and in CPSC’s PGA Message Set CATAIR Implementation Guide. This page did not open that guide, so it does not print an eFiled attestation. For paper and electronic certificates under sections 1110.9(b) and (c), the same paragraph prints this attestation: “I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.” The sheet does not sign that sentence.

The cartons in the photograph have no marks. A SKU that exists only on the purchase order is in the same position until a certificate prints that SKU. WS-2208 is that case. The pallet does not tell you which certificate belongs to which carton.

What the broker receives

Hand the broker a finished Full set or a finished Reference set, plus this sheet. A finished Full set has all seven values copied from the source file for that one product, and the broker receipt stays blank until the broker’s own note says those values were received. A finished Reference set has the three identifiers copied from the registry, and the same blank-until-the-note rule. Until that note exists, the cell stays blank.

ACE can accept the entry while CPSC rejects the certificate data. CBP CSMS #69382435, sent July 29, 2026, says CPSC implemented the eFiling PGA message set requirements on July 8, 2026, and that the eFiling of certificate data is mandatory. The same bulletin says ACE can accept an entry that has no CPSC message set, or a message set missing some CPSC data, when the CATAIR PGA spec is followed, and that CBP will not generate an SX reject in those cases. CPSC may still respond in an SO message, including a rejection of the CPSC data, and may enforce on an entry that lacks eFiling data when it was required.

The FAQ, as fetched October 18, 2026, says CPSC does not intend to ask CBP to deny entry solely because certificate data was not eFiled, and does not intend initially for ACE to send reject messages for missing PGA data, only warning messages. CPSC still enforces certificate requirements and can ask CBP to seize non-compliant products, and it intends to adjust an entry line’s risk score from the certificate data. Read the bulletin and the FAQ together. A warning, or an entry ACE accepts, is not a reason to mark the broker receipt cell as a CPSC clearance.

Keep the CPSC message, if one arrives, with the file. Do not overwrite the broker receipt with it. The broker receipt records what the broker got. The SO message records what CPSC said about the data.

Where this sheet stops

This sheet ends when each SKU has its seven values or its three Reference identifiers, the source file and the provider are named, the buyer check is done, and the broker receipt is either filled from the broker’s note or still blank because that note has not arrived. It does not test the product, choose citation codes, or file the entry.

A lot inspection is a different record. The quality-control inspection guide is where sampling the goods is planned. Do not paste an inspection result into the Product Test Date row and call the certificate matched.

Quantities and carton numbers are a different record. The invoice and packing list cross-check matches those lines. Do not paste a carton count into the Product ID cell.

Who files the US entry is a different record. The DDP checklist linked above stays blank when the offer does not name the filer.

More buyer records in this lane sit in the freight and logistics category.

How this page was checked

The seven elements, the seven Product ID types, Full and Reference, the registry’s separation from ACE, the July 8th, 2026 and January 8th, 2027 dates, the Disclaim encouragement, and the applicability limits follow the CPSC eFiling FAQ fetched October 18, 2026. The response last-modified header was October 17, 2026. The importer-of-record role and the IOR number follow the CPSC importers page fetched the same day, also last-modified October 17, 2026. The one-product rule, the English-language rule, the address lines inside the seven labels, the mail-import registry timing, and the paper attestation follow the eCFR text of 16 CFR part 1110 fetched the same day. That page states it is not an official legal edition of the CFR, and it prints the source line 90 FR 1843, January 8, 2025, unless otherwise noted. The Cornell text of 15 USC 2063, last-modified September 28, 2026, was used for section 2063(a)(1), section 2063(g)(1), section 2063(g)(2), and section 2063(g)(4). This check did not fetch a House reprint. The ACE accept-versus-CPSC-reject boundary follows CBP CSMS #69382435, bulletin July 29, 2026, fetched October 18, 2026. No Product Registry screen was opened, and the CATAIR guide was not opened, so no registry field labels or CSV headers were added from a screen. No shipment was filed for this article. Updated October 18, 2026.