CPSC certificates and eFiling: straight answers.

Anyone who imports or makes a consumer product that is subject to a CPSC rule, ban, standard or regulation. A children’s product — designed or intended primarily for children 12 and under — needs a Children’s Product Certificate based on testing by a CPSC-accepted laboratory. Other regulated products need a General Certificate of Conformity based on a test of each product or a reasonable testing program. For imported products, the importer is the certifier.

Source: 15 U.S.C. 206316 CFR 1110.7

Since July 8, 2026, importers must file the data from their certificate electronically with U.S. Customs and Border Protection at the time of entry — either the full data (a Full PGA message set) or three identifiers pointing to a certificate stored in CPSC’s Product Registry (a Reference PGA message set). Products entered from a Foreign Trade Zone follow on January 8, 2027.

Source: 90 FR 180016 CFR 1110.1390 FR 45917

If you import the regulated products you sell, yes. CPSC treats sales through an online marketplace, even between consumers, as commercial transactions. The importer is a party eligible to make entry — the owner, purchaser, consignee or an authorized broker; CPSC will not typically treat a consumer buying for personal use as the importer. Tell us how your goods ship, and we point you to the rule text that fits your case.

Source: CPSC eFiling FAQ16 CFR 1110.3

No. CPSC states that there is no Section 321 (de minimis) exemption for eFiling: any product that requires a certificate needs an eFiled certificate, whatever the value of the shipment.

Source: CPSC eFiling FAQ16 CFR 1110.13

Since July 8, 2026, certificate data for products imported by mail must be entered in the Product Registry before the product arrives. From October 22, 2026, CPSC will require an eFiled certificate — a Full or Reference message set — on mail shipments, through CBP’s new Entry Type 13 process.

Source: 16 CFR 1110.13CPSC mail guidance91 FR 37801

CPSC says it does not intend, for now, to ask CBP to deny entry solely for missing eFiled data, and that ACE will at first send warnings rather than rejections. It also says it will keep enforcing certificate requirements and keep asking CBP to seize non-compliant products. The statute allows refusal of admission for products not accompanied by a required certificate.

Source: CPSC eFiling FAQ15 U.S.C. 2066

No. Children’s products must be tested by a laboratory accepted by CPSC for the tests required; CPSC publishes the list. We tell you which tests to order, and build the certificate from the lab’s reports. Lab fees are paid to the lab.

Source: 15 U.S.C. 2063CPSC lab list

No. Customs entries are filed by you or your licensed customs broker. We give your broker what CPSC requires in the entry: the three Registry identifiers, or the full certificate data.

Source: CATAIR v2.5

No. We never log into your account and never submit anything to CPSC. We deliver your certificate data as a CSV file in CPSC’s official bulk-upload template, with a step-by-step import guide based on CPSC’s own. You — or your customs broker, or a Collection Editor in your Business Account — import it, check it and certify it. The Business Account itself is opened by the importer, and its administrator must be one of the importer’s employees.

Source: CSV guide v3Registry guide v316 CFR 1110.15

You do. The importer (or, for U.S.-made products, the manufacturer) is the certifier and remains legally responsible for the certificate’s validity, accuracy, completeness and availability, even when someone else types or imports the data. We prepare the documents; we do not sign, attest or certify anything with CPSC or CBP.

Source: 16 CFR 1110.15Registry FAQ v1.4

Periodic testing by a CPSC-accepted lab is due at least once a year; up to every two years with a production testing plan; up to every three years with continued testing at an ISO/IEC 17025-accredited lab. A material change — design, process or component source — calls for new testing and a new certificate.

Source: 16 CFR 1107.2116 CFR 1107.23

If every size meets the tight-fitting dimensions and labeling of 16 CFR 1615.1(o), the garment is not children’s sleepwear under part 1615 and falls under the clothing standard, part 1610, instead. The lead rules apply, and CPSC staff applies the phthalates rule to sleepwear for children 3 and under. Our sample file works through exactly this case.

Source: 16 CFR 1615.1(o)CPSC sleepwear FAQCPSC example CPC

One certificate. Each certificate must describe only one product; CPSC treats apparel from the same material in several styles, sizes and colors as one product if it was manufactured and tested together. Products that differ by a material change need separate certificates.

Source: 16 CFR 1110.13Registry FAQ v1.4

After a written, fixed quote, you pay in advance through a secure card link. The delivery clock starts when we have your payment and the documents on our checklist. If we miss the delivery date in your quote, we refund that product’s fee in full.

No. Admission decisions belong to CBP and CPSC. We promise what we control: a complete certificate, delivered by the date in your quote, at the price in your quote.

PortCert is a small, distributed team that prepares CPSC certificates and eFiling data. We work in writing — email only, no calls — and reply within one U.S. business day. We are not a law firm, a testing laboratory or a customs broker, and nothing we deliver is legal advice.