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CPSC eFiling for Amazon sellers: what you must file in 2026-2027

Applies to US-based and foreign sellers who import consumer products into the United States and sell them on Amazon or other marketplaces. Summarized from official CPSC sources linked inline. Not legal advice.

Since July 8, 2026, every imported consumer product that needs a CPSC certificate must have that certificate's data electronically filed ("eFiled") with CBP at entry. Before that date you only had to have a certificate and show it on request. Now the data has to travel with the shipment. For sellers who ship by international mail, the requirement starts on January 20, 2027. There is no de minimis exemption: a $40 parcel of children's toys is covered just like a container (CPSC eFiling Quick Start Guide).

1. Are you the "importer"? Probably yes

CPSC puts the eFiling duty on the importer. For CPSC's certificate rule, the importer of a finished product is "a party eligible to make entry for the merchandise pursuant to CBP statutes and regulations, who may be an owner, purchaser, consignee, or authorized customs broker" (CPSC mail guidance, Oct 2026, quoting the final rule). If you are the Importer of Record on your shipments, as most private-label sellers who ship to FBA are, the obligation is yours. Your freight forwarder or broker may transmit the data, but they can only send what you give them.

If you buy finished goods from a US distributor that imported them, the distributor is the importer and files. You still need the certificate for your records, and Amazon may ask for it.

2. Does your product need a certificate at all?

A certificate is needed when a CPSC rule, ban, standard or regulation that requires certification applies to the product. Three quick tests:

• Is it a children's product? It is if it is designed or intended primarily for children 12 and under. Then you need a Children's Product Certificate (CPC) based on testing by a CPSC-accepted third-party lab. At minimum this usually covers lead content (1278a) and lead paint (1303). Toys and child care articles add phthalates (1307), and toys add the applicable ASTM F963 sections.
• Is it a general-use product covered by a specific rule? Examples are bicycles, bicycle helmets, lighters, mattresses, rugs, products with button/coin batteries, portable fuel containers, clothing storage units and adult clothing textiles. These need a General Certificate of Conformity (GCC).
• Neither? Then no certificate is needed. If your HTS code is on CPSC's flag list, you can file a Disclaim instead.

Our free checker walks through these questions. The HTS flag list page shows whether your tariff code is one CPSC and CBP flag in ACE. Remember that CPSC says the list "does not encompass all HTS codes where an electronic certificate may be required".

3. What goes into an eFiled certificate

16 CFR 1110.11 sets the content. Whichever way you file, you need:

1. Product identification: at least one ID (GTIN/UPC, model number, SKU, serial number, registered number or alternate ID) and a description that lets someone match the certificate to the product.
2. Every applicable rule, listed separately as citation codes.
3. The certifier (the importer for imported goods), with full address, email and phone.
4. The records custodian, a person or always-staffed position, with full contact details.
5. The date of manufacture (month/year at minimum) and the manufacturer's name, address and contact details.
6. The most recent test date, plus the name and contact details of each lab whose results you rely on. Where you claim an exemption, list the testing exclusion code instead.
7. The attestation. When filing electronically, the system supplies it.

Most Amazon sellers already hold lab reports but not a correctly built certificate. A common mistake is to treat the lab report as the certificate. The certificate is your statement, built from the report.

4. Two ways to file: Full PGA vs Reference PGA

Full PGA Message Set: your customs broker types all certificate elements into the entry each time. This works, but brokers charge for it and repeat data entry invites errors.

Reference PGA Message Set: you load the certificate once into CPSC's free Product Registry. For each entry the broker then sends only three IDs: Certifier ID, Product ID and Version ID. For a seller importing the same SKUs repeatedly, this is usually cheaper and less error-prone (Product Registry FAQ).

The Registry accepts a bulk CSV upload with strict formatting rules. See our guide to Product Registry CSV errors.

5. A practical checklist for a private-label seller

1. List your SKUs with HTS codes and decide for each: CPC, GCC, or no certificate (Disclaim).
2. Collect the latest test report for each SKU. For a CPC, check that the lab is CPSC-accepted for each rule using CPSC's lab search, and note its CPSC lab ID.
3. Get from your factory the legal name, street address, email and phone, and the month/year of manufacture for each production lot.
4. Decide who is the records custodian and what the record-access contact is.
5. Build the certificate and Registry row. Our generator turns a test report and these facts into an English certificate PDF and a Registry CSV row in the official 83-column template format.
6. Run the CSV through the validator before uploading.
7. Upload to the Product Registry from your business account and certify. Then send your broker the three Reference IDs for each SKU.
8. When a new production lot ships, create a new version with the new manufacture date and, if retested, the new test date.

6. What happens if you don't file

Entries missing required CPSC data can be held for review, and shipments of noncompliant products can be refused admission. CPSC says filing a voluntary Disclaim where no certificate is required "may benefit an importer's risk score" (CPSC HTS list, Oct 2026). Marketplace compliance uploads, such as documents you give Amazon, do not replace the eFiling made with your customs entry.

7. Common questions

I ship small parcels directly to customers from overseas. Mail shipments now need CBP's Entry Type 13, and CPSC will require eFiled certificates for them starting January 20, 2027 (CPSC mail guidance). Express couriers file entries for you, but you still have to provide the certificate data.

My product is for adults but sits in a flagged apparel HTS code. Adult apparel meeting the conditions in 16 CFR 1610.1(d)(1) or (d)(2) can use Disclaim B with intended use code 130.006. See Disclaim A vs B.

Do I need a US lab? No. The lab must be CPSC-accepted for the rules tested (for CPCs), and many accepted labs are outside the US.

Key dates

• July 8, 2026: eFiling mandatory for imported regulated products (formal and informal entries); new certificate content rules (16 CFR 1110.11) apply to domestic and imported products.
• January 8, 2027: products entered for consumption or warehousing from a Foreign Trade Zone.
• January 20, 2027: international mail shipments filed under CBP's new Entry Type 13.
• There is no de minimis exemption for eFiling. Sources: Final Rule (90 FR 1800), CPSC mail guidance (Oct 2026).