CPSC eFiling for Batteries: flagged HTS codes and citation codes

CPSC's October 2026 HTS list places 5 HTS codes in the Batteries category (5 CP1) across 1 HTS heading(s).

What the flags mean. CPSC and CBP flag these HTS codes in ACE. CPSC's list labels CP2 as "CPSC Certificate Related Data is Required" and CP1 as "CPSC Certificate Related Data May be Needed". CPSC says the ~600-code list covers HTS codes that likely include a product subject to a mandatory standard or deemed high-risk, but it does not cover every HTS code where a certificate may be required. The importer must eFile whenever a certificate is required, whatever the HTS code. If your product needs no certificate, a voluntary Disclaim may be filed, which CPSC says may benefit your risk score (CPSC HTS list, Oct 2026; Disclaim A vs B).

Rules commonly cited for Batteries

1263.3: 16 CFR 1263.3: Requirements for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries
1263.4: 16 CFR 1263.4: Labeling of Button Cell or Coin Battery Packaging
2056e: 15 USC 2056e: Special Packaging for Button Cell or Coin Battery

Children's versions (designed or intended primarily for children 12 and under) need a Children's Product Certificate based on third-party testing; general-use versions need a GCC when a rule applies. Use the free checker to narrow it down.

Flagged HTS codes

HTS	Official description (USITC HTS)	CPSC flag
`8506.10.00.10` 8506100010	Primary cells and primary batteries; parts thereof › Manganese dioxide › Button and coin cell batteries	CP1 CPSC Certificate Related Data May be Needed Changed CP2 to CP1 on 2026-09-08
`8506.40.10.10` 8506401010	Primary cells and primary batteries; parts thereof › Silver oxide › Having an external volume not exceeding 300 cm3 › Button and coin cell batteries	CP1 CPSC Certificate Related Data May be Needed Changed CP2 to CP1 on 2026-09-08
`8506.50.00.10` 8506500010	Primary cells and primary batteries; parts thereof › Lithium › Button and coin cell batteries	CP1 CPSC Certificate Related Data May be Needed Changed CP2 to CP1 on 2026-09-08
`8506.60.00.10` 8506600010	Primary cells and primary batteries; parts thereof › Air-zinc › Button and coin cell batteries	CP1 CPSC Certificate Related Data May be Needed Changed CP2 to CP1 on 2026-09-08
`8506.80.00.10` 8506800010	Primary cells and primary batteries; parts thereof › Other primary cells and primary batteries › Button and coin cell batteries	CP1 CPSC Certificate Related Data May be Needed Changed CP2 to CP1 on 2026-09-08

Deadlines

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).

Free tools: Check whether your product needs a CPC/GCC and eFiling · Validate your Product Registry CSV · Generate a certificate + Registry CSV

Source: CPSC HTS list (Oct 2026), USITC HTS.