The U.S. Consumer Product Safety Commission (CPSC) has introduced electronic Filing (eFiling). This initiative will require importers to electronically submit the data elements from the Certificate of Compliance, as per 16 CFR 1110, for regulated consumer products. This is done through the Automated Commercial Environment (ACE) system managed by U.S. Customs and Border Protection (CBP). This critical initiative not only streamlines certification but also enhances efficiency and accuracy, safeguarding the well-being of consumers and facilitating smoother market access for businesses like yours.
Purpose and benefits
Purpose:
The eFiling system streamlines the certification process, reduces paperwork, and improves data accuracy.
Benefits:
- Reduced Hold Times: Electronic certification data minimises the need for physical document inspections, speeding up goods clearance.
- Cost Efficiency: Importers incur lower costs due to fewer holds and inspections.
- Enhanced Focus: CPSC can allocate resources to higher-risk shipments, improving overall product safety oversight.
Process of eFiling
The CPSC offers importers two methods for entering certificate data into the eFiling system:
The Reference Message Set via the Product Registry:
Importers enter certificate data into the CPSC Product Registry first, then submit a unique ID through the ACE system. The Product Registry allows importers to manage and view their certificates and grant access to third parties like brokers or testing laboratories.
The Full Message Set:
Importers submit all certificate data directly through the CBP’s ACE system.
Types of certificates of compliance
Children's Product Certificate (CPC):
This certificate is required for children's products, ensuring they comply with applicable safety rules such as those for lead content, phthalates, and small parts.
General Certificate of Conformity (GCC):
This certificate applies to general-use products, confirming compliance with relevant consumer product safety standards.
Certificate content
According to the Supplemental Notice of Proposed Rulemaking (SNPR) by the CPSC on December 8, 2023, the Certificate of Compliance for eFiling must include:
- Identify the finished product(s) covered by the certificate. Certifiers must provide at least one of the following unique identifiers: global trade item number (GTIN), model number, registered number, serial number, stock keeping number (SKU), universal product code (UPC), or alternate identifier, along with a sufficient description to match the finished product to the certificate.
- The list of all applicable CPSC rules, regulations, bans or standards, identified separately, to which the finished product is certified.
- Identify the party certifying compliance of the finished product(s), including the party's name, street address, city, state or province, country or administrative region, electronic mail (email) address, and telephone number.
- Identify and provide contact information (consisting, at a minimum, of the individual's name, street address, city, state or province, country or administrative region, email address, and telephone number) for the individual maintaining the records.
- Provide the date (month and year, at a minimum) and place (including a manufacturer name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were manufactured, produced, or assembled. For manufacturing runs over a series of days, provide the initial date of manufacture (month and year, at a minimum).
- Provide the most recent date and places (including the name of each third-party conformity assessment body or other party on whose testing the certificate depends: name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were tested for compliance with the applicable CPSC rule(s), ban(s), standard(s), or regulation(s).
- Include the following attestation:
I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.