Tech Watch: CPSC Publishes eFiling Final Rule

On January 8, 2025, the U.S. Consumer Product Safety Commission (CPSC) published the Final Rule for eFiling in the Federal Register to revise the requirements for certificates of compliance (CoC) in 16 CFR 1110. The final rule will come into effect on July 8, 2026, for all CPSC-regulated consumer products and substances subject to the final rule. However, there are some exceptions. For products and substances imported into a foreign trade zone (FTZ) and subsequently used for consumption or warehousing, the final rule will apply from January 8, 2027.

The Final Rule applies to imported consumer products subject to a mandatory safety standard, including de minimis shipments, and requires the electronic filing of CoC data.

The CPSC offers importers two methods for entering certificate data into the eFiling system:

• The Reference Message Set via the Product Registry: Importers enter certificate data into the CPSC Product Registry first, then submit a unique ID through the ACE system. The Product Registry allows importers to manage and view their certificates and grant access to third parties like brokers or testing labs.
• The Full Message Set: Importers submit all certificate data directly through the CBP’s ACE system.

The required CoC data elements to be electronically submitted are:

• identification of the finished product;
• party certifying compliance;
• each consumer product safety rule to which the finished product has been certified;
• date and place the finished product was manufactured;
• when and where the finished product was most recently tested for compliance; and
• contact information for the person maintaining test records.

The Final Rule will also require private labellers to certify domestic products (unless the manufacturer certifies the product).

The CPSC is inviting up to 2,000 additional importers to sign up for the eFiling voluntary stage to test out the systems before eFiling becomes mandatory. Trial requests can be made at eFilingsupport@cpsc.gov.

Source: https://www.govinfo.gov/content/pkg/FR-2025-01-08/pdf/2024-30826.pdf

The Eurofins Softlines & Hardlines network of companies has a long history of assisting the consumer products industry with compliance. Our experts have designed solutions to ease the transition to eFiling, ensuring your products comply and reach the U.S. market efficiently.

For questions and additional information, please contact Dr. Pratik Ichhaporia
(Pratik.ichhaporia@cpt.eurofinsus.com, +1-669-837-2257) or David Hong (David.Hong@cpt.eurofinscn.com)