CPSC eFiling Is Live: The Test Data You Need From Your Factory
Since July 8, 2026, importers of regulated consumer products must file certificate data at entry. Most of that data starts at the factory, so here is what to collect and when.
In this piece 8 sections
CPSC eFiling requires importers of regulated consumer products to send certificate of compliance data to customs at the time of entry. It became mandatory on July 8, 2026. The data includes where and when the product was made and tested, and by which lab. Most of that information lives at your factory, so collect it before goods ship.
I spent years on the receiving end of containers that should never have left the factory. The paperwork problems were often worse than the product problems. eFiling puts that paperwork in front of the government before your goods clear, and a gap now means a held entry instead of an awkward email.
This explainer is for small and mid-sized importers who buy finished consumer goods from factories in China, Vietnam and the rest of Asia. It covers what eFiling actually requires, what you need from your supplier, and how to fold it into your existing quality checks.
What Changed on July 8, 2026?
The Consumer Product Safety Commission (CPSC) switched certificate filing from "available on request" to "submitted at entry." Before July 8, an importer had to hold a certificate and produce it if asked. Now the certificate data travels electronically with the customs entry. Products imported through Foreign Trade Zones have until January 8, 2027.
The CPSC framed the change around targeting. In its announcement that eFiling is now in effect, the agency said the program followed alpha and beta pilots between 2016 and 2024. It also said compliant importers should see fewer unnecessary inspections. The flip side is that missing or sloppy data now flags a shipment early.
One point is worth stating plainly. The CPSC says eFiling does not add new testing or certification obligations. If you were skipping certificates before, you were already out of compliance. eFiling just makes that visible at the border.
Which Certificate Do Your Products Need?
Most regulated products need one of two certificates. Which one depends on who the product is for. Getting this right decides whether your factory can use its own tests or must use an outside lab.
The table below sets out the difference.
| Certificate | Applies to | Testing basis |
|---|---|---|
| Children’s Product Certificate (CPC) | Products designed mainly for children 12 and under | Third-party testing at a CPSC-accepted lab |
| General Certificate of Conformity (GCC) | General-use products covered by a CPSC rule | Testing or a reasonable testing program |
| No certificate | Products with no applicable CPSC rule | Not required, but other laws may apply |
The CPSC’s guidance on the Children’s Product Certificate is strict on one point. Testing must be done by a third-party lab that the CPSC has accepted. A factory’s in-house lab report does not qualify, however good the lab looks.
General-use products have more flexibility. The CPSC page on the General Certificate of Conformity says it must be based on a test of each product or a reasonable testing program. In practice, that can include factory testing, but you still need records to back it up.
The Seven Data Points Your Factory Must Supply
Both certificates rest on the same seven elements. Some come from you as the importer. Most come from the factory or its lab. Here is who usually holds each one.
- Product identification. A description that ties the certificate to a specific product and model. You and the factory agree this together.
- Applicable safety rules. Every CPSC rule that applies. Your lab or compliance adviser should confirm the list.
- Certifying party. The importer’s name, address and phone number. This one is yours.
- Records contact. The person who keeps the test records. Usually yours, sometimes a broker.
- Date and place of manufacture. At least month and year, plus the factory address. Only the factory knows this.
- Date and place of testing. When and where the tests were done. This comes from the lab report.
- Lab details. The third-party lab’s name, address and phone, for children’s products. Also from the lab report.
Items five through seven are where importers get stuck. A factory that changes production lines or moves orders to a sister plant will change the place of manufacture. If nobody tells you, your certificate is wrong.
How Does eFiling Fit Into Pre-Shipment Inspection?
eFiling fits naturally into the same visit as your pre-shipment inspection. The inspector is already at the factory, checking the finished goods against your order. Add a short document check to their brief. They confirm the production date and location, photograph lot labels, and collect the current lab report for the exact model being shipped.
In our experience, adding this step costs about fifteen minutes of inspector time. It saves days when a broker asks for a missing date at entry. I now treat the certificate data as part of the inspection report, not a separate admin task.
The inspector can also check that the tested sample matches production. A lab report on a red version of a toy does not cover a blue version made with a different paint supplier. Material changes need new tests, and the factory will not always volunteer that it switched suppliers.
The same visit is a good time to collect traceability records. If you also buy cotton, aluminum or other higher-risk inputs, our guide on checking your China suppliers against the UFLPA Entity List covers which supplier documents to ask for at the same time.
Who Certifies When You Buy Through a Trading Company?
The importer of record certifies the product, even if a trading company handled the factory. That catches out buyers who never met the real manufacturer. The trading company may forward a lab report, but you sign off on the certificate data.
This creates a practical problem. Trading companies often hide the factory name to protect their margin. eFiling needs the real place of manufacture, so that arrangement no longer works for regulated goods.
Ask the trading company for the factory name and address in writing before you place the order. If they refuse, treat it as a warning sign. In my experience, the good trading companies share it under a non-circumvention agreement. The ones that will not share it often cannot tell you which plant made last month’s batch either.
Check the lab report against that address. The report should name the same factory, or at least the same group, and the sample date should sit close to the production run you are buying.
Common Gaps That Hold Up an Entry
Most eFiling problems come down to stale or mismatched data. These are the ones I see most often when working with importers this year.
- Expired test reports. A report from two years ago may not reflect the current materials or production.
- Wrong factory address. The order moved to a second plant, but the certificate still names the first one.
- Missing rule citations. The report covers lead content but not the small-parts or labeling rules that also apply.
- In-house lab reports for children’s goods. These do not meet the third-party requirement.
- No production date. The factory never recorded month and year by lot.
Each gap is cheap to fix before shipment and expensive after. A held entry runs up storage and port charges for every day it sits. Our tariffs and customs section covers how those landed costs add up.
Setting Up Your Supplier for eFiling
Start with a written request to every factory that makes a regulated product for you. Ask for the current lab report for each model, the production address and a commitment to report any change in materials or factory. Put that commitment into your purchase order terms.
Next, decide how you will store the data. The CPSC offers a Product Registry where importers can save certificate data once and reference it in filings. Your customs broker may manage this for you, but you are still the party certifying the product. Check what your broker needs and in what format.
Volume is a reason to get this right. According to the Census Bureau’s trade data, the US still imported about $308.7 billion of goods from China in 2025, even after a 30% drop. A large share of consumer products in that flow is now subject to eFiling.
A fair counterpoint is that small importers may feel this is a broker’s problem. Brokers can transmit the data, but they cannot invent it. If your factory never recorded a production date, no broker can file one.
What eFiling Means for Your QC Routine
eFiling turns certificate data into a pre-shipment requirement. The rules on testing have not changed, but the timing has. You now need production dates, factory addresses and current lab reports before the container sails, not after a customs query.
The simplest next step is to add a certificate check to your inspection checklist this month. Ask your inspector to confirm the seven data points on the next order, and fix any gaps with the factory before you pay the balance.
