CPSC eFiling Guide
- What CPSC eFiling is?
- What CPSC eFiling changes, and what stays the same
- Which deadlines matter and which products are broadly in scope
- The types of certificates and test reports needed for products that require eFiling
- What filing information is generally required and the main filing methods
- Risks to sellers and the platform if products are not eFiled
- Support available to Full Service, as well as POP and Local sellers
The following documents are required when eFiling with the CPSC
- Valid, up-to-date Children's Product Certificate (CPC) for products intended for children 12 and younger
- Valid, up-to-date General Certificate of Conformity (GCC) for certain general use products (see list below)
- Valid, complete and up-to-date test reports, conducted by a CPSC accredited laboratory within the last 365 days and which covers all required components
CPC vs. GCC at a glance
A simple way to explain the difference:- CPC is generally used for children’s products, such as toys and other products made for children, and is tied to children’s product safety requirements
- GCC is generally used for non-children’s consumer products that are subject to applicable CPSC rules or standards
Test reports: CPCs and GCCs must be supported by test reports. Children's Products must be tested by third-party laboratories that are accredited by the CPSC, and generally observe testing requirements from ASTM International (a standards organization), such as the ASTM F963 standard. In general, test reports should follow the entire ASTM program, but in particular they should include testing for:
- lead
- phthalates
- small parts
- button cell batteries
- magnets
- lithium ion batteries
- among other tests.
GCCs must be based on a "reasonable testing program", the details of which can be found in this website: General Certificate of Conformity (GCC) FAQ.
GCC testing may be done in house, or by a third-party, but does not require CPSC accreditation.
What information is generally filed
At a high level, eFiling uses certificate-related product data such as:- finished product identification
- the party certifying compliance
- the consumer product safety rule or rules the product was certified against
- date and place of manufacture
- the location and time of the most recent compliance test
- contact information for the person maintaining testing records
Options for eFiling
Sellers may either file through a reference message set or a full message set. For sellers that are repeatedly importing into the United States, the reference message set is probably the best option. Please refer to the CPSC's Quick Start Guide on eFiling for more details.1. Reference message set
This is generally used when certificate data has already been registered in advance and the filer can submit reference details instead of the full certificate information each time. It is often the more practical option for repeat imports of the same product.Importers choosing to eFile through the reference message set must register a business account and eFile their products through the CPSC Product Registry.
2. Full message set
This is generally used when the filer submits the full certificate data at the time of entry. It may be more common for 1-time or lower-repeat import situations.For education purposes, the simplest rule is: repeat products often benefit from a reference-based approach, while one-off situations may rely more on full filing.
Disclaimers (Exemptions)
This is generally used when a product is imported under a code associated with CPSC review, but the specific product does not require certificate filing data. In that case, the filer may submit a disclaimer rather than certificate details, but is not required to. (However, this is considered a good practice and can improve sellers' risk scores with CPSC.)For more information, visit the Citations, Testing Exclusions, and Disclaims guide.
Best Practices
To ensure eFiling readiness, sellers should adopt the following repeatable habits:- Check if your product requires eFiling with the CPSC: confirm whether the product is subject to a mandatory CPSC safety requirement before advising on filing expectations.
- Match the product to the right certificate: children’s products generally require CPC, while many non-children’s consumer products subject to CPSC rules require GCC.
- File early: do not wait until shipment is about to move. Teams should encourage stakeholders to have certificates and filing information ready in advance.
- Repeat imports should use reference message set, 1-time imports should use full message set
- Check seller type before promising support: education support may apply broadly, but filing support does not.
- Use careful language on edge cases: if product scope or certificate type is unclear, confirm before giving final guidance.
Common Readiness Risks and Consequences
The biggest risks are usually not about understanding the rule in theory. They come from incomplete or inaccurate readiness in practice.Common risks include:
- missing CPC or GCC documentation
- outdated or unsupported certificate records
- inaccurate filing data
- confusion about whether a product needs CPC or GCC
- assuming low-value or de minimis shipments are excluded
- assuming education support means filing support
- Incomplete test reports
- Test reports not performed by CPSC accredited laboratories
- shipment delays
- additional scrutiny at the border
- seizure risk
- notices of violation
- downstream listing and operational disruption
Common mistakes to prevent
A few mistakes are especially worth calling out in training:- Waiting until the deadline is close: readiness usually takes longer than expected because documentation has to be checked, not just collected.
- Treating all seller types the same: support expectations differ.
- Focusing only on the certificate name: the supporting data elements matter too.
- Overpromising certainty on edge cases: where product scope is unclear, teams should guide stakeholders to confirm applicability instead of guessing.