The United States Consumer Product Safety Commission (CPSC) has released an updated list of Harmonized Tariff Schedule (HTS) codes that will be impacted by its new electronic filing (eFiling) requirement. The revised list offers importers greater clarity on which products will need an eFiling of a Certificate of Compliance (COC) when the rule becomes mandatory on July 8, 2026.
What is the CPSC eFiling requirement?
The CPSC is modernizing its compliance process by requiring importers to electronically file COCs for regulated consumer products. A COC is a document in which a manufacturer or importer certifies that a product complies with all applicable consumer product safety rules.
Currently, this documentation is often provided on paper. The new eFiling rule mandates that specific data from the COC must be submitted electronically to U.S. Customs and Border Protection (CBP) at the time of entry. This includes details like:
• A description of the finished product.
• The identity of the party certifying compliance.
• Each CPSC safety rule to which the product is certified.
• The date and location of manufacturing and testing.
• Contact information for the person who maintains testing records.
This requirement applies to all CPSC-regulated products that need certification.
Key update: The HTS code list is now shorter
The CPSC recently published a revised list of HTS codes that it believes are likely to include products requiring an eFiling. The agency reduced the number of codes on this list to help the trade community better understand which products will be flagged in the system.
It’s important to note that this list is not exhaustive. It serves as guidance for when importers can expect automated flagging. Importers are still responsible for ensuring compliance for any regulated product, even if its HTS code is not on the list.
View the updated HTS code list
Important compliance deadlines
The mandatory enforcement date for the eFiling rule is quickly approaching.
• July 8, 2026: The rule takes effect for most regulated consumer products imported into the U.S.
• January 8, 2027: The rule takes effect for goods imported into a foreign-trade zone (FTZ) and later entered for consumption.
Starting on these dates, non-compliance will have significant consequences for importers.
The risks of not being prepared
The CPSC has made it clear that it will begin enforcement actions on day one. Shipments associated with mandatory HTS codes that have missing or questionable eFiling data will be prioritized for examination. The consequences can include:
• Significant shipment delays: CPSC examinations can hold cargo for up to 60 days. Importers will be responsible for all associated costs, such as storage and manipulation fees.
• Increased scrutiny: Non-compliance can lead to a higher importer risk score, resulting in more frequent inspections and holds in the future.
• Penalties: Importers may face potential civil or criminal penalties for failing to meet their compliance obligations.
How you can prepare now
The best way to ensure a smooth transition is to prepare your business now. The CPSC encourages importers to participate in its voluntary eFiling program. This allows you and your trade partners to test systems, refine internal processes, and familiarize yourselves with the requirements in a penalty-free environment.
The CPSC offers a robust library of resources to help you get started, including training videos, FAQs, and quick-start guides. You can find these valuable tools on the official CPSC eFiling webpage.
By taking proactive steps today, you can protect your business from costly delays and ensure you are ready when the rule becomes mandatory.