US CPSC eFiling of
Certificates of Compliance
From 8 July 2026, importer must electronically file a Certificate of Compliance with US Customs (CBP via ACE) at the time of entry for consumer products subject to a CPSC safety rule. De minimis has ended — there is no value threshold, so this applies to every shipment, at any value. This page tells you which products are flagged, whether you need a CPC or a GCC, what to test and where, and how to file it.
No value threshold — a certificate is filed on every shipment of a covered product, at any value.
Applies to children’s (CPC) and general-use (GCC) certified products alike.
Foreign-Trade-Zone entries have a later start date.
Each finished-product certificate covers a single product.
These HTS codes are currently blocked on Xindus. We have paused new bookings on the CPSC-flagged codes below while we revamp the platform. Filing reopens 11 July 2026.
Questions or an urgent shipment in the meantime? Write to xborder@xindus.net.Find your product or HTS code
Three ways in: search a product name (tell us who it's for) → get the likely HTS codes, testing and labs. Search an HTS code → get what it means, testing and labs. Or pick a category → see every code with its meaning; click any code for its detail.
CPC vs GCC — and where self-certification is fine
CPC — Children’s Product Certificate
For products designed or intended primarily for children 12 or younger.
- Third-party testing is mandatory at a CPSC-accepted laboratory. You cannot self-certify the safety tests.
- A tracking label is required on the product and packaging.
- The importer/manufacturer issues the CPC, backed by the accredited lab’s report.
GCC — General Certificate of Conformity
For general-use (non-children’s) products subject to a CPSC rule.
- Self-certification is allowed. First-party or any qualified lab testing is acceptable.
- Must be based on a test of each product, or on a reasonable testing program.
- You still issue and hold a valid certificate and produce it on demand.
What a robust self-certification program looks like
Self-certifying (GCC) is not “no testing.” If CBP or CPSC asks, you must show it's real:
- A documented test report (first-party or lab) for each certified product or material.
- A written reasonable testing program: what you test, how often, and what triggers a re-test.
- Change control — a material, component, supplier or design change forces a re-test before the next certification.
- Records retained and the certificate furnished to CBP, CPSC and your distributors/retailers on request (16 CFR Part 1110).
One-off, per lot, or on change? Certify the right thing.
The most common over-compliance mistake is re-testing every SKU, every shipment. You usually don’t have to.
Before first import
Certify the product before it’s imported or distributed. This is the baseline certificate on file.
Periodic, not per-shipment
Under a documented production-testing plan, periodic third-party testing is required at least once a year — not on every lot (16 CFR Part 1107).
Re-test on any material change
A change to materials, components or process triggers material-change testing before the next certification — for CPC and GCC.
New supplier = potential re-test
Treat a new factory or component supplier as a material change. Re-test the affected component, not necessarily the whole product.
Test the material once, reuse it
Under component-part testing (16 CFR Part 1109) you can test a fabric, ink, trim or plating once per supplier/batch and rely on it across every product that uses it.
No mandatory periodic 3rd-party test
General-use products need a current, reasonable testing program — re-test on material or design change, but no annual CPSC-accepted-lab requirement.
Flagged categories → standard & CFR
“CPC / GCC” means it depends on whether the item is a children’s product — use the finder.
| Category | Path | HTS | CFR | Standard |
|---|---|---|---|---|
| All-Terrain Vehicles (ATVs) | CPC / GCC | Ch. 87 | 16 CFR Part 1420 | ANSI/SVIA 1 |
| Bicycle Helmets | CPC / GCC | Ch. 65 | 16 CFR Part 1203 | CPSC Bicycle Helmet Standard |
| Bicycles | CPC / GCC | Ch. 87 | 16 CFR Part 1512 | Requirements for Bicycles |
| Button Cell & Coin Batteries | CPC / GCC | Ch. 85 | 16 CFR Part 1263 | Reese's Law |
| CB Antennae | GCC | Ch. 85 | 16 CFR Part 1204 | CB Base-Station Antennas |
| Carpets and Rugs | CPC / GCC | Ch. 57 | 16 CFR Parts 1630 & 1631 | Surface Flammability (FF 1-70 / FF 2-70) |
| Carriages and Strollers | CPC | Ch. 87 | 16 CFR Part 1227 | ASTM F833 |
| Child Chairs | CPC | Ch. 94 | 16 CFR Parts 1231 / 1232 / 1237 | ASTM F404 & related |
| Cigarette & Multipurpose Lighters | GCC | Ch. 96 | 16 CFR Parts 1210 & 1212 | Lighter Child-Resistance |
| Clothing | CPC / GCC | Ch. 61, 62, 65 | 16 CFR Parts 1610 · 1615 · 1616 · 1120 | Apparel flammability / Sleepwear / Drawstrings |
| Drywall | GCC | Ch. 68 | 15 U.S.C. §§ 2056c / 2057e | Gypsum board emissions |
| Fireworks | GCC | Ch. 36 | 16 CFR Parts 1500 & 1507 | Fireworks Devices |
| Gates and Enclosures | CPC | Ch. 39, 44, 73 | 16 CFR Part 1239 | ASTM F1004 |
| Imitation Jewelry | CPC / GCC | Ch. 71 | 16 CFR §§ 1500.89 & 1500.91; ASTM F2923 | ASTM F2923; lead & cadmium limits |
| Infant Sleep Products | CPC | Ch. 94 | 16 CFR Parts 1218 / 1236 & related | ASTM F3118 & product-specific |
| Lawn Mowers | GCC | Ch. 84 | 16 CFR Part 1205 | Walk-Behind Power Lawn Mowers |
| Matchbooks | GCC | Ch. 36 | 16 CFR Part 1202 | Matchbooks |
| Mattresses | CPC / GCC | Ch. 39, 63, 94 | 16 CFR Parts 1632 & 1633 | Cigarette ignition (FF 4-72) & Open-flame |
| Other Children's Furniture | CPC | Ch. 94 | 16 CFR Part 1261 & related | ASTM F2057 & related |
| Pacifiers | CPC | Ch. 39 | 16 CFR Part 1511 | Pacifier Requirements |
| Poison Prevention Packaging | GCC | Ch. 24, 36 | 16 CFR Part 1700 | Child-Resistant / Senior-Friendly (PPPA) |
| Shoes | CPC / GCC | Ch. 64 | 15 U.S.C. §§ 1278a & 2057c; 16 CFR 1500 | Children's footwear: lead / phthalates / small parts |
| Toys | CPC / GCC | Ch. 32, 34, 85, 95 | 16 CFR Part 1250; 16 CFR 1500.14(b)(8) | ASTM F963; Art materials LHAMA / ASTM D4236 |
CPSC-accepted labs in India
For a CPC you must use a CPSC-accepted laboratory. These global labs run CPSC-accepted operations in India. For a GCC, first-party or any qualified lab is fine.
| Laboratory | India locations | Typical scope |
|---|---|---|
| SGS India | Chennai, Gurugram, Bengaluru, Tirupur | Textiles, toys, jewellery, hardlines |
| Intertek India | Gurugram, Bengaluru, Tirupur, Delhi | Softlines, toys, electrical, children’s products |
| Bureau Veritas (BV) CPS | Mumbai, Gurugram, Tirupur, Bengaluru | Toys, textiles, hardlines, EMC |
| TÜV SÜD South Asia | Bengaluru, Gurugram, Mumbai | Toys, electrical, hardlines |
| UL Solutions India | Bengaluru, Gurugram | Electrical, batteries, hardlines |
Jewellery: precious vs base metal, and when you can disclaim
Jewellery is the category importers most often over-comply on. Two questions settle almost everything — what is it made of, and who is it for — and a short list of disqualifiers does the rest.
1 • What it’s made of → HTS 7113 vs 7117
Precious metal → HTS 7113
Genuine gold (≥10k), sterling silver (≥925), platinum group.
- Not on CPSC’s flagged list: This heading isn't in the eFiling HTS list at all.
- CPSC treats these metals as presumed to meet the lead limit — no lead test on the precious metal itself.
- The presumption covers only the precious metal. Solder, clasps, plating and base-metal parts are not covered — test those.
Base metal → HTS 7117
Brass, silver-plate, silver-tone, alloy — costume / fashion jewellery.
- On CPSC’s flagged list (imitation jewellery). The eFiling check triggers at entry.
- No precious-metal lead pass: Leaded brass is common — it's exactly what the total-lead limit targets.
- What you actually file then depends on who it's for — below.
“Silver imitation jewellery” is a contradiction in customs terms: genuine silver is 7113 (precious); silver-tone or plated costume is 7117 (base). The metal decides the heading.
2 • Who it's for → the three outcomes
Disclaim
Adult base- or precious-metal jewellery with no battery, no hazardous magnet and no children’s angle. Your broker files a disclaim at entry — a positive declaration it isn't subject to CPSC certification. No CPC, no GCC.
CPC — third-party
Sized, themed or marketed for kids → children's product. CPC backed by a CPSC-accepted lab: total lead ≤100 ppm, cadmium & nickel per ASTM F2923, small-parts, tracking label, annual periodic testing.
GCC — Reese's Law
Light-up / LED pieces with a button or coin cell → 16 CFR Part 1263 applies to consumer products, not just children's. Needs a GCC (or CPC if it's also a kids' item).
3 • What “disclaim” actually means
- Positive legal statement: It's a statement in the ACE message set that the product is not subject to a CPSC certificate requirement — not simply the absence of a filing.
- Not “no rules”: California Prop 65 and state lead / cadmium / nickel laws still apply to that adult brass ring regardless of the federal disclaim.
- Defensible or it's false: You must be able to show the piece genuinely isn't a children's product and has no battery / magnet trigger. The audience call is where sellers get burned.
- ASTM F2999 is voluntary: The adult jewellery standard, ASTM F2999, is voluntary — best practice, not federally mandated. Adopting its lead / cadmium / nickel-release limits is how you back up the disclaim if it's ever challenged.
4 • What disqualifies you from disclaim
Marketed, sized or themed for ≤ 12 → CPC + third-party. Judged on how it's presented, not on what you label it.
Reese's Law (16 CFR 1263) → GCC for consumer products; CPC if it's also children's.
Strong, swallowable magnets pull in the magnet rule.
Part of a toy or a play set → ASTM F963 children's-toy regime, not adult disclaim.
Plain adult metal / costume jewellery — no battery, no magnet, no kids' angle — disclaims. Add a battery, a magnet, or a child audience and it becomes a certificate.
5 • “I have 5,000 designs” → test materials, not SKUs
The number that drives cost isn't the design count — it's how many distinct materials those designs are built from. Component-part testing (16 CFR Part 1109) lets you test a material once and reuse the result across every design that uses it.
- Count materials, not designs: 5,000 rings & earrings from (say) 2 brass alloys + 3 platings + 2 enamels + 1 earring-post metal ≈ 8 test streams — not 5,000.
- Test each material once per supplier / batch — alloy, plating bath, enamel or coating, post metal — then map it across every SKU that uses it.
- XRF-screen first: Cheap X-ray screening on each distinct material weeds out the clearly-compliant; send only failures or unknowns for full lab certification.
- Consolidate suppliers: Consolidate suppliers to shrink the material count — fewer alloys and platings means fewer tests.
- Earring posts → check nickel: Pierced posts sit against skin; nickel release is what catches sellers who only tested for lead.
- Map SKU → material set once, so a single material result covers hundreds of designs and any audit is traceable.
Same principle as the testing-cadence section: certify the material, reuse it — it turns an impossible per-design bill into a handful of tests.
The CPSC Product Registry & what to hand your broker
eFiling has three parts: a valid certificate, the CPSC Product Registry, and the CBP ACE filing at entry. Register once, prepare the seven data elements, and your broker files them with each entry.
Registering
- Create a Business Account on the CPSC eFiling Product Registry.
- Set your certifier identity — a Certifier ID you assign yourself (this, not your IOR number, is what anchors the account).
- Set your trade-party privacy preference (whether your identity is visible to other filers).
Do you need to be the Importer of Record to register?
No — and this is where two separate things get confused. Owning the account is not the same as being legally responsible at entry.
- No IOR number needed to open an account: The account is anchored by the Certifier ID you assign yourself, not by an IOR number. CPSC supports non-IOR filers — mail shipments have no IOR at all, yet must still enter their data into the Registry.
- So a manufacturer or seller can create their own account: Load every SKU and own their certificate data — without having to sit inside a US importer’s account.
- But owning the data ≠ being the certifier at the border: For normal commercial entries CPSC still holds the Importer of Record (or the owner / purchaser / consignee the broker names) legally responsible for the certificate. Creating the account does not move that responsibility onto you.
- The clean pattern for exporters: You create the account and load the data; whoever files at entry references it in the ACE message set. Your customs broker has to confirm they will file against your (or a third party’s) Certifier ID before you rely on it.
The 7 data elements on every certificate
Filing at entry
Your customs broker transmits these seven elements in the CBP ACE PGA message set at the time of entry, for each covered product. Hand them the seven elements per SKU before the shipment moves — that’s all they need.
What happens if you file without this data
Without the certificate / seven data elements in the ACE message set, the entry is held or rejected at the flagged HTS line.
Storage, demurrage and per-diem charges pile up during the hold.
The goods, and issue civil penalties for a false or missing certificate.
Repeated failures mean more inspections and holds on future shipments.
A voluntary “disclaim” message (declaring an item is not subject to CPSC certification) can be filed where appropriate and may help your risk score — but only when the product genuinely isn’t covered.
CPSC Guidance PDF & Flagged List
Review official guidance notes issued by CPSC (April 2026), outlining the HTS code list and eFiling instructions.
CPSC Guidance & HTS Code List
Download the official PDF reference material containing detailed filing instructions and the 590+ CPSC-flagged HTS codes.