On 1 October 2026, the U.S. Consumer Product Safety Commission (CPSC) published an updated version of its HTS guidance for the electronic filing (eFiling) of Certificates of Compliance. The updated document reorganises the approximately 600 Harmonized Tariff Schedule (HTS) codes that CPSC has identified as likely to include products subject to a mandatory consumer product safety standard or that are otherwise considered high risk.
Since 8 July 2026, CPSC has been using specific product flags within U.S. Customs and Border Protection's (CBP) Automated Commercial Environment (ACE) to identify shipments that may require certificate data. The updated guidance now categorises HTS codes according to the flag assigned by CPSC:
In addition, a small number of HTS codes had their flag designations changed since the April 2026 version — notably, liquid nicotine product codes (HTS 2404.12) were reclassified from CP2 to CP1. The full details of all changes are available in the Change Log tab of the updated document.
The new format is intended to provide greater clarity to importers, customs brokers, manufacturers, and other supply chain stakeholders by distinguishing between HTS codes that may trigger certification review and those that generally require certificate data submission.
We are ready to support your eFiling compliance. Our team can assist with submitting your certificate data to the CPSC Product Registry, enabling Reference Message Set filing through your customs broker. We can also help you review your product portfolio against the updated CP1 and CP2 code lists to identify any gaps in your current eFiling program.
Please reach out to us to discuss your eFiling compliance readiness.
Source:
CPSC Guidance and HTS List for Filing of Electronic Certificates: https://www.cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx