Does CPSC eFiling Apply to my Buy-In Group?

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

If you found this page because someone in your vendor group just mentioned something about "CPSC" or "eFiling" and you went scouring the internet because you don't have a clue what they are going on about, welcome! You aren't behind, you're just catching this information in exactly the same way most find out about it.

So let's talk about this eFiling thing, yeah?

Compliance and eFiling are two different things.

I want to first separate these because they are already getting tangled together with this new eFiling regulation coming (July 8, 2026).

Product safety compliance (shortened to "compliance") is a set of regulations related to safety that a product must follow. This usually includes testing, labeling, and certification. The certification is a self-created document that would describe a product, indicate the manufacturer, date of manufacturing, and how the product complies with the regulations it has to follow. This certifcation, typically called a Children's Product Certificate or General Certificate of Conformity, is usually just kept in your records for just in case a government official needed to see it.

eFiling is the system that the Consumer Product Safety Commission (CPSC) and US Customs and Border Protection (CBP) have created to help the import process a little more efficient in regards to catching unsafe products. Instead of those certificates being kept in your records, you now will share the information with the government prior to shipping products into the US.

If you've been importing finished products without the compliance aspect, we may have a bit of catching up to do before your next shipment.

Will I need to do this eFiling thing or not??

It depends on the category your products fall under. Some things you import might require eFiling while others might not. Here's a rough breakdown:

General use and adult products (bags, tea towels, bedding, etc.) typically aren't regulated by the CPSC specifically. Maybe some labeling of fiber content and country of origin, but nothing really under the CPSC specifically. That means that you won't have to do the eFiling if you are importing this kind of product.

Adult clothing, specifically, has a bit of a catch here. Adult clothing does have a regulation under the CPSC to follow: Flammability. Adult clothing can be exempt from Flammability testing under certain circumstances (like tees made with "flat" fabric) and when it is exempt from testing, it doesn't require specific certificate to be made. On the flip side, adult clothing that has a "fuzzy" surface will generally require testing and would then be required to have a certificate made. Because the adult clothing does have a specific CPSC regulation to follow, you will have to do the eFiling. For the clothing that is exempt, you'll have a specific 'disclaim' to enter into the system. For the clothing that required testing, you'll have more information to enter that is related to the testing and testing lab.

Children's products, all of them, have specific CPSC regulations to follow. Children's products always require a certificate regardless of needing testing or not. If you happen to have a product that has all exemptions from testing (like a plain tee), then, like the adult clothing, you will have a number of disclaims to enter. If your product required testing, you'll have more information related to the testing and testing lab here too.

Why call out buy-in groups?

Aside from the influx of people who have joined my groups with this worry, the thing I really want to talk about is the structure of importing when you have multiple sellers on a single buy-in shipment.

Every seller/distributor of products is responsible for ensuring the compliance and safety of every product they sell. It doesn't matter how small a business is or even if the seller treats it like a business. So every seller who is importing a regulated product will be required to do the eFiling.

The eFiling system only allows for one account per business (yes, buy-in groups are businesses, even if you are charging at-cost prices), but allows for the account owner to add 'trade partners'. These partners may be other owners in the business, other business owners, brokers, managers, or lab reps.

When the buy-in is a bunch of sellers together, one of the sellers will generally act as the 'host'. The person communicating with the manufacturer, taking the payments from the other sellers, making the payments to the manufacturer, etc. This person will now be the responsible party for the eFiling as well.

Now, don't get me wrong, the host always had this same responsibility for imports, nothing has really changed. It's just now the responsibility is even more clear to the CPSC and CBP.

What you need to determine

  1. Is the product regulated by the CPSC? It's a bit of a mine field, but the CPSC has a nice tool that can help you figure it out: Regulatory Robot
  2. Does it require a CPC (for children's products) or GCC (for adult & general use products)?
  3. Has testing actually been done? Check that it is under 1 year old, covers exactly your product(s), uses CPSC-specific testing (not EU), and was done by a CPSC-accepted lab?
  4. Who is handling the eFiling submission?

The mechanics of eFiling

Getting started is probably the hardest part of the system as their documentation isn't ideal. Once you get into the system and can see the actual thing, it'll go much smoother. [This] user guide is one of many that can be helpful in setting everything up. Below I've added a few of my own takeaways.

Product data and user permissions are organized by "Product Collections", so your first step will be to determine how you want to set up your 'collections' (if any) and who (if anyone) will have access to manage information within a collection. For buy-in groups, one way to organize might be by manufacturer/vendor so that they can be invited to enter information into that specific collection without being able to see other collections. A collection could also be organized by product type to organize information that may only be related to it (Sleepwear Flammability testing for children's sleepwear for example).

You then will need to determine which "Message Set" to use:

  • Full PGA > Use this for limited number of regulated consumer products or not repeatedly importing the same product covered by the same certificates. (one-off buy-in of hair bows, children's clothing from different manufacturers, etc.)
  • Reference PGA > Use this for products that are imported repeatedly and are covered by the same product certificates. (children's shoes from the same manufacturer in various colors and styles)

You can then begin to enter in information by single certificates, or upload a CSV file to upload multiple certificates' data.

One thing that I found important to understand from the get-go is the way they utilize unique identification codes for products. It will be ideal to create a system that is easy to remember, decode, and serialize when creating 'Product ID' as the first ID provided will be the primary distinguisher going forward. If you import a product multiple times, that Product ID will have a Version ID attached to it.

Thankfully, the eFiling system doesn't require uploads of actual paperwork. Instead, everything is done through text data and uses the same information as the certificates. To make things even easier, the CPSC has identified regulatory codes and exemption citations they will be using in the system (download the XSLX file here).

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).

What now?

Importing can be a daunting thing to begin with and this eFiling doesn't make it any easier, initially. If you are just learning about all of this compliance stuff, you'll want to start there before touching the eFiling system. So here's what to do next:

  1. Determine what your products are and if they are regulated by the CPSC.
  2. If they are regulated by the CPSC, do they have proper testing and certification?
  3. If they do not have proper testing & certification, work to get that done as soon as possible.
  4. Figure out who will be considered the main Business Account Administrator (the person legally responsible for all products and information).
  5. Determine if you will hire a broker or other person to assist in entering information into the eFiling system. If you utilize a broker, talk to them before creating an eFiling Business Account.
  6. Decide how you will organize product collections and how you will identify products.
  7. Start entering data for every shipment prior to it reaching a US port.
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