New US Compliance Rule for Imported Consumer Products

Do you ship consumer products to the United States? If yes, there is a new compliance requirement taking effect July 8, 2026, that may affect your shipments. Here is what it means and what you should do before the deadline.

What Is Changing?

The U.S. Consumer Product Safety Commission (CPSC) is introducing mandatory electronic filing of Certificate of Compliance information for certain imported consumer products. This takes effect July 8, 2026, under a final rule amending 16 CFR Part 1110.

Previously, proof of compliance was often only requested on a case-by-case basis. Starting July 8, certificate data must be submitted electronically at the time of import through the Automated Commercial Environment (ACE). It's the system used by U.S. Customs and Border Protection (CBP).

Shipments missing the required information may face:

• Customs delays
  
• Additional inspections
  
• Refusal of entry into the United States
  

At launch, ACE will issue warnings for missing eFiling data instead of outright rejections, and CPSC does not currently plan to deny entry solely for missing eFiling data. However, missing data may still increase the likelihood of holds, inspections, or enforcement action. Full compliance by the effective date is strongly recommended.

Which Products Are Affected?

Note that not all consumer products are subject to this requirement. It only applies to products covered by a mandatory CPSC safety rule, ban, standard, or regulation.

The CPSC has released a sample list of Harmonized Tariff Schedule (HTS) codes that they will flag for review. Based on currently available information, products commonly associated with these requirements include:

• Toys
  
• Children's apparel and furniture
  
• Bicycles
  
• Helmets
  
• Button cell batteries
  
• Mattresses
  
• Carpets and rugs
  
• ATVs
  
• Imitation jewelry
  
• Certain household goods and consumer electronics
  
• Other regulated consumer products
  

Specific safety regulations and HTS classifications will determine product eligibility. Again, not every item in these categories will automatically require electronic filing.

Adult-worn apparel made from exempt fabrics and certain other product types may fall under CPSC enforcement discretion, meaning no certificate is required at this time. However, enforcement discretion can be revoked with relatively short notice, so it is worth staying informed.

What Type of Certificate Is Required?

The type of certificate depends on your product:

• Children's products (designed primarily for children 12 and under). They require a Children's Product Certificate (CPC), backed by third-party testing at a CPSC-accredited laboratory.
  
  
• General-use regulated products. These require a General Certificate of Conformity (GCC). First-party testing through a reasonable testing program may qualify for these products.
  

Certificates must include:

• All applicable rules and standards
  
• Most recent test date
  
• All testing labs use
  
• Any testing exclusions relied upon
  

Starting July 8, 2026, the results must also list the component-part test on the certificate.

What are we doing?

We understand that this may be a significant change for some. However, please rest assured that our team is working both internally and with our customs broker to determine how to integrate compliance information while minimizing disruption to your shipping workflow.

We will continue to provide updates as details are finalized.

How to Prepare

Here are practical steps you can take now:

1. Check whether your products are regulated. Use the CPSC Regulatory Robot at cpsc.gov/Business--Manufacturing/Regulatory-Robot/Safer-Products-Start-Here to identify whether a mandatory safety rule applies to your products.
   
   
2. Cross-reference your HTS codes. Review the CPSC's flagged HTS code list, available at the CPSC eFiling Document Library, to confirm whether your products are subject to eFiling.
   
   
3. Collect certificate data from your suppliers. You will need the manufacture date, manufacturing location, test dates, and lab information for each regulated product. For children's products, confirm third-party testing was completed at a CPSC-accredited lab.
   
   
4. Verify existing certificates are complete. Starting July 8, certificates must include component-part test results and declare any testing exclusions. Review your current certificates against the updated requirements in 16 CFR Part 1110.
   
   
5. Subscribe to CPSC updates. Monitor cpsc.gov/eFiling for rule changes, especially if your products currently fall under enforcement discretion.
   

Key Dates

• Now through July 7, 2026. Voluntary registration and test filings are now open in the CPSC Product Registry (for the first 2,000 participants). CPSC is not flagging HTS codes during this period, so there is no risk to your shipments while you prepare.
  
  
• July 8, 2026. Mandatory eFiling begins for all imported regulated consumer products. CPSC will begin flagging HTS codes in ACE.
  
  
• January 8, 2027. The eFiling requirement extends to products imported through Foreign Trade Zones (FTZ).
  

Useful Resources

• CPSC eFiling Program: cpsc.gov/eFiling
  
• CPSC Product Registry: cpsc.gov/eFiling-CPSC-Product-Registry
  
• eFiling Document Library: cpsc.gov/eFiling-Document-Library
  
• CPSC Regulatory Robot: cpsc.gov/Business--Manufacturing/Regulatory-Robot/Safer-Products-Start-Here
  
• CPSC-Accredited Lab Finder: cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation
  
• HTS Code Reference: hts.usitc.gov
  
• eFiling Support: [email protected]
  

How Stallion Can Help

If you are unsure where to start, our team is here to help you work through the requirements.

We are available to:

• Review your HTS codes against the CPSC-flagged list
  
• Walk you through the certificate data requirements
  
• Advise on the Full PGA vs. Reference PGA filing options
  
• Coordinate with you on implementation timelines
  

Reach out to our team, and we will help you figure out the next steps before the July 8 deadline.

Jose Sagun

Jose is Stallion's Senior Business Analyst. He helps improve the company’s shipping processes, works closely with delivery partners, and looks at shipping data to find the best prices for our customers. Outside of work, Jose has a passion for running, regularly completing 5k and 10k runs, with the goal of running a full marathon in the near future.