Eurofins CPSC eFiling Services

eFiling: Welcome to the Future of Import Compliance!

In today’s fast-paced global market, ensuring your products meet safety standards before they reach consumers is more crucial than ever. The U.S. Consumer Product Safety Commission (CPSC) has introduced electronic Filing (eFiling). This initiative will require the importers to electronically submit the data elements from the Certificate of Compliance, as per 16 CFR 1110, for regulated consumer products. This is done through the Automated Commercial Environment (ACE) system managed by U.S. Customs and Border Protection (CBP). This critical initiative not only streamlines certification but also enhances efficiency and accuracy, safeguarding the well-being of consumers and facilitating smoother market access for businesses like yours.

Discover how eFiling can transform your import processes and how Eurofins Softlines & Leather - Toys & Hardlines network of companies can support you every step of the way.

Purpose and Benefits

Purpose:

The eFiling system streamlines the certification process, reduces paperwork, and improves data accuracy.

Benefits:

• Reduced Hold Times: Electronic certification data minimises the need for physical document inspections, speeding up goods clearance.
• Cost Efficiency: Importers incur lower costs due to fewer holds and inspections.
• Enhanced Focus: CPSC can allocate resources to higher-risk shipments, improving overall product safety oversight.

Process of eFiling

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.

Image source: CPSC

Types of Certificates of Compliance

• Children's Product Certificate (CPC):
  This certificate is required for children's products, ensuring they comply with applicable safety rules such as those for lead content, phthalates, and small parts.
  
  
• General Certificate of Conformity (GCC):
  This certificate applies to general-use products, confirming compliance with relevant consumer product safety standards.

Certificate Content

According to the Supplemental Notice of Proposed Rulemaking (SNPR) by the CPSC on December 8, 2023, the Certificate of Compliance for eFiling must include:

• Identify the finished product(s) covered by the certificate. Certifiers must provide at least one of the following unique identifiers: global trade item number (GTIN), model number, registered number, serial number, stock keeping number (SKU), universal product code (UPC), or alternate identifier, along with a sufficient description to match the finished product to the certificate.
• The list of all applicable CPSC rules, regulations, bans or standards, identified separately, to which the finished product is certified.
  
  
• Identify the party certifying compliance of the finished product(s), including the party's name, street address, city, state or province, country or administrative region, electronic mail (email) address, and telephone number.
  
  
• Identify and provide contact information (consisting, at a minimum, of the individual's name, street address, city, state or province, country or administrative region, email address, and telephone number) for the individual maintaining the records.
  
  
• Provide the date (month and year, at a minimum) and place (including a manufacturer name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were manufactured, produced, or assembled. For manufacturing runs over a series of days, provide the initial date of manufacture (month and year, at a minimum).
  
  
• Provide the most recent date and places (including the name of each third-party conformity assessment body or other party on whose testing the certificate depends: name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were tested for compliance with the applicable CPSC rule(s), ban(s), standard(s), or regulation(s).
  
  
• Include the following 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.

Compliance Requirements

Products imported for consumption, warehousing, or commerce distribution must be certified to ensure they meet the applicable safety standards.

Historical Background and Implementation Timeline

• 2008: The Consumer Product Safety Improvement Act (CPSIA) mandates importers test and certify products.
• 2013: Notice of Proposed Rulemaking (NPR) suggests electronic filing of certificates.
• 2016: Alpha Pilot tests the PGA Message Set and Product Registry.
• Fall 2023 - Spring 2024: Beta Pilot expands participant testing and IT development.
• 2024: Final rulemaking expected to be completed.
• 2025: Full implementation of eFiling requirements.

Challenges and Considerations

While eFiling streamlines the certification process, importers must ensure compatibility with the ACE system. Additionally, partner with industry experts like Eurofins that can facilitate electronic submission of Certificate of Compliance data elements.

For the latest detailed information on eFiling, visit the CPSC eFiling page.

How Can the Eurofins Softlines & Leather - Toys & Hardlines Network of Companies Help?

Eurofins Softlines & Leather – Toys & 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.

Contact us to avoid supply chain disruptions and ensure compliance with regulations.

Watch the webinar recording for more!

To support brands and manufacturers in adapting to this new process, we are pleased to have invited Arthur Laciak, eFiling Program Specialist, Office of Import Surveillance, CPSC, as our featured speaker, where he provided insights and guidance on:

• eFiling Essentials: Understand the critical steps in the eFiling process for the Certificates of Compliance
• eFiling Timeline: Understand the critical steps and timelines for eFiling
• Quick Start Guide: Get a detailed overview of the CPSC eFiling Quick Start Guide to streamline your efforts
• Best Practices: Discover tips and strategies for efficient and error-free eFiling

Ready to Streamline Your Import Process?

Contact Softlines & Leather – Toys & Hardlines network of companies today for a personalised consultation. Our experts are here to ensure your products comply with U.S. safety standards efficiently and effectively.

Don’t let compliance hurdles slow down your business. Reach out to us now and stay ahead of the curve!