Which Products Require CPSC eFiling?

Trying to understand if eFiling is required for your product? In this guide, we explain how you can determine if that is the case based on the amended version of Part 1110 published in January 2025.

How can I determine if eFiling is required for my product?

CPSC eFiling is expected to become mandatory for finished products manufactured outside the United States that are already subject to certification requirements. This is written in the amendment to Part 1110, which was published in January 2025:

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§ 1110.1 Purpose and scope

This part specifies the entities that must issue certificates for finished products in accordance with section 14(a) of the Consumer Product Safety Act (CPSA), as amended, 15 U.S.C. 2063(a); specifies certificate content, form, and availability requirements that must be met to satisfy the requirements of section 14 of the CPSA; requires importers to file certificates electronically (eFile) with U.S. Customs and Border Protection (CBP) for imported finished products that are required to be certified; and clarifies which provisions of this part apply to component part certificates. This part does not address the type or frequency of testing necessary to support a certificate.”

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Certification in this context refers to the Children’s Product Certificate (CPC) and the General Certificate of Conformity (GCC).

As such, eFiling is likely required if:

1. You import finished products to the United States

2. Your product requires a Children’s Product Certificate (CPC), or;

3. Your product requires a Certificate of Conformity (GCC)

This, in turn, depends on whether your product is classified as a children’s product or covered by a general product safety rule.

Children’s Products

eFiling will become mandatory for children’s products intended for children aged 12 years or younger. This is due to the fact that children’s products are subject to the Children’s Product Certificate (CPC) requirement.

Examples of covered children’s products include:

• Toys
• Children’s clothing
• Children’s furniture
• Baby carriers
• Strollers
• Pacifiers
• Baby bottles
• Other children’s products

General Use Products

eFiling is also applicable to products covered by one or more product safety rules that mandate a General Certificate of Conformity (GCC).

Examples of such products include:

• Carpets
• Bicycles
• Products containing magnets
• Products containing button cell batteries
• Wearing apparel
• Mattresses
• Clothing storage units

Note that general product safety rules are not age group dependent but apply regardless of the intended age group of the product. Further, some rules apply to products that contain certain components, such as magnets or button cell batteries, rather than being applicable to certain product types.

Which products are exempt from eFiling?

eFiling is generally not required for products that are either not children’s products or covered by a general product safety rule.

As such, eFiling is not expanded to all or even most products imported to the United States – at least for now.

It is also possible that the CPSC will exempt certain products that fall within the scope of the CPC and GCC requirements in the future.

FAQ

Is eFiling required for low-value shipments?

Yes, eFiling will be required for products that are required to be certified regardless of the customs value.

This makes sense, as eFiling would otherwise unfairly burden US-based businesses importing bulk shipments while cross-border sellers shipping low-value parcels would be exempt.

What does it mean if my product is not subject to eFiling requirements?

Then you don’t need to submit via eFiling, but you must still comply with other requirements.

Is CPSC eFiling mandatory for toys and other children’s products?

Yes, eFiling is required for products defined as toys and children’s products, as a Children’s Product Certificate (CPC) is required.

Is CPSC eFiling mandatory for furniture?

eFiling may be required for children’s furniture or other furniture covered by general product safety rules. Here are some examples:

• Full-size cribs
• Bassinets and cradles
• Play yards
• Clothing storage units

Is CPSC eFiling mandatory for magnets?

It is likely that eFiling will be required for magnets as these are covered by Part 1262, which in turn requires either a CPC or a GCC.

Is CPSC eFiling mandatory for batteries?

We have not found any source stating that eFiling will be required for all batteries. That said, button cell batteries are covered by Part 1263, which requires either a CPC or a GCC. It is likely that eFiling will be required for button cell batteries for that reason.

Is CPSC eFiling mandatory for electronics?

We have not found any source stating that electronic products will be subject to eFiling by default. However, electronic toys or electronics containing button cell batteries will likely be subject to eFiling requirements.