Does CPCS eFiling Apply to me for Supplies?

[NOTE: This is a work in progress. Information in this post may change slightly.)

Starting July 8, 2026, the CPSC is requiring importers of regulated consumer products to electronically file their Certificate of Compliance data at the time of entry, instead of simply keeping it on file. This is called eFiling, and it has prompted a lot of questions from handmade sellers who import materials and supplies.

So now the question is... Does it apply to you?

First, in case you are new around here, I want to make sure this is very clear:

eFiling doesn't actually create a new requirement. It only changes how a requirement is met.

Certificates of Compliance (CPCs for children's products, GCCs for general-use/adult products) have been required since 2008. eFiling does not change who needs a certificate. It only changes how that certificate's data reaches the government: Electronically, at the time of import, rather than kept on file and produced upon request.

This means the question isn't "is eFiling new and scary," it's "did I already need a certificate?" If the answer was no, it's still no (generally... read on).

 

Raw materials and components: NO CERTIFICATE = NO EFILING

If what you're importing is a raw material or component, like fabric by the yard, loose beads, hardware, ribbon, trim, batting, thread, etc. none of that ever required a CPC or GCC, because none of it was considered a finished consumer product. Since eFiling only applies to finished consumer products, these raw materials don't fall into that realm.

Easy peasy, mac and cheesy.

 

Where it gets a bit hectic: BLANKS

This is the bucket that causes the most confusion, because the word "supply" gets used fairly loosely in our world.

Many of you have shops based on added embroidery, HTV, DTF, paint, or dyes to blank products. For you the blank product is a supply. But to the CPSC, it is not, it is treated as a finished product because it technically is. So now you have to figure out if your blank product required the manufacturer to follow any specific regulations for it.

Most adult/general-use blank products don't fall under any specific regulation requiring testing. Bags and tea towels are great examples here. Since there is no specific testing regulation, there is no GCC to be made and eFiling does not apply.

Adult clothing sometimes requires a GCC. If it required Flammability testing, it required a GCC. If it was exempt from Flammability testing (due to being plain surfaced fabric like tees), then no GCC was required. Because adult clothing required you to comply with a testing regulation, eFiling will apply.

The exempted adult clothing is why I said 'generally' above. Even though the exempted tee didn't require a GCC to be made for your records, eFiling still applies. There will be a specific "disclaim" for you to use in the system.

Children's products always require a CPC regardless of needing testing or not. So if you are importing blank children's products, like bodysuits, hats, stuffed toys, tees, and child-specific bags, you are importing a product that originally required a CPC and eFiling will apply.

 

QUICK REFERENCE

  • Importing raw materials/components only → No certificate required → eFiling does not apply
  • Importing blank children's products as your "supply" → CPC required → eFiling applies
  • Importing blank adult apparel → May require GCC (flammability) or disclaim → eFiling applies
  • Importing blank general use products → No certificate required → eFiling does not apply*
  • Not importing anything at all → eFiling does not apply to you

*This statement is based on the typical blank product used by makers and my not apply to all general use products. Always double check before assuming exception.

IF YOU'RE NOT SURE WHICH BUCKET YOU'RE IN

The safest move is to confirm, not assume, especially with blanks, since "it's just my supply" is the exact phrasing that leads people to miss a requirement that's already been applied to their products for years. A good resource to double check is the CPSC's Regulatory Robot.

One last thing to note

eFiling with the CPSC is Part 1 of a two-part process. The second part is submitting the information to CBP's ACE system. You can do the second part yourself, through a broker, or through the courier (FedEx, DHL, UPS).

If you have not used a broker and have not filed with the ACE system, it is likely that you've always relied on the courier and they may have additional information that they collect when you do the 'customs form' for them. If you are not filing the customs form with the courier, you need to connect with whomever it is that does that part of the shipping to make sure you know what information they will want to be able to complete their side of things (Certifier ID, Product ID, Version ID).

Inside the eFiling account, you (as the importer) are able to invite trade partners, like the manufacturer/shipper, to add data related to the product(s) in that shipment. Once they enter their information, you can then approve and certify the product, and submit the identifying information to the applicable party (courier, broker, ACE system).

For a deeper walk-through of importing requirements generally, see "What Do I Do When Importing?" [here]. If your shipment has already been held up at the border, see "My Product Was Stopped at Customs" [here].
Back to blog