Questions sellers ask about CPSC certificates and eFiling.
One question per page, answered in the first paragraph, then explained with dates, rule citations and the official source for each point. Not legal advice. Shorter answers live on the FAQ.
Last updated: November 9, 2026 · 30 questions
Deadlines and shipping
- I ship to U.S. customers by international mail. What happens on October 22, 2026?
CBP and CPSC both moved their mail requirements to Jan. 20, 2027; Registry data before arrival still applies now.
- Did CPSC change its eFiling date for international mail? What it means for importers
Yes: CPSC moved eFiled certificates for mail to Jan. 20, 2027, the date CBP set for mandatory Entry Type 13.
- Did CBP change the rules for foreign importers of record? What it means for sellers shipping from abroad
Yes: from Jan. 5, 2027, a foreign importer of record needs CTPAT validation or a CTPAT-validated broker.
- I sell from outside the U.S. and ship to U.S. customers. Who has to certify and eFile?
The importer, which can be you as a foreign seller — rarely the U.S. consumer who bought the item.
Marketplaces and suppliers
- Amazon is asking for a Children’s Product Certificate. What must it contain?
A standalone CPC with the seven required elements, issued by the importer or U.S. maker — a lab report alone is not a CPC.
- Can I use my supplier’s CPC, or do I need my own?
You issue your own CPC, but you may build it on your supplier’s tests — with due care and the right documents.
- Can I write my own Children’s Product Certificate?
Yes — it is free and needs no approval, as long as it has the seven required elements and rests on proper tests.
- My factory in China sent a lab report. How do I check the lab is CPSC-accepted?
Find it on CPSC’s list, check its scope test by test and its status — and whether a factory-owned lab is firewalled.
How many certificates, and for how long
- Does a Children’s Product Certificate expire?
No date is printed on it, but periodic retests — usually yearly — and material changes mean reissuing it.
- Do I need a separate CPC and lab test for each color, size or SKU?
One certificate per product — sizes and colors of one garment are often one product; a different paint makes a separate one.
- How much does a Children’s Product Certificate (CPC) cost?
The certificate is free to create; the cost is in CPSC-accepted lab testing and periodic retests.
Which rules apply
- My product is for adults or collectors, labeled 14+. Do I still need a CPC?
A 14+ label alone does not settle it: four factors decide whether it is a children’s product that needs a CPC.
- I make children’s products by hand in the U.S. Do I need a CPC and lab tests?
A CPC, yes. Small Batch registration can replace lab tests for Group B rules only — never for lead in paint or small parts.
- Do children’s clothes need a CPC, and which tests apply?
Yes: lead content, lead in paint for coatings and scrapable prints, and flammability — with exclusions that still go on the certificate.
- I’m importing bicycle helmets and customs asks for a GCC. What do I need?
Adult helmet: GCC on a reasonable testing program. Children’s helmet: CPC and a CPSC-accepted lab.
- I sell children’s pajamas. Which CPSC rules, tests and labels apply?
Flame-resistance tests under part 1615 or 1616, or the tight-fitting route with its measurements, hangtag and label — plus a CPC either way.
- Are kids’ loungewear sets and bathrobes “sleepwear” under CPSC rules?
Usually yes: CPSC staff treats children’s loungewear and at-home robes as sleepwear, whatever the product is called.
- Can I sell 100% cotton pajamas for kids in the U.S.?
Usually only as tight-fitting sleepwear or infant garments: CPSC says untreated 100% cotton typically fails the sleepwear flame tests.
- Do kids’ pajamas need a new flammability test for every production lot?
Yes for flame-resistant sleepwear: every fabric unit (up to 5,000 yards) and garment unit (up to 500 dozen) is tested, after prototype tests.
- Which CPSC tests does a children’s pillow need: lead, phthalates, flammability?
A CPC with lead tests on foam, zippers and prints; phthalates only for toys and toddler items; no federal flammability test.
- Does the packaging of a children’s product need CPSC lab testing for the CPC?
Not for disposable bags and boxes; yes for a reusable bag or case kept with the product. The tracking label still applies.
- Do children’s leather shoes need CPSC lead testing? Which parts are exempt?
A CPC; dyed leather needs no lead test; soles, metal parts and coatings are tested; no phthalate or flammability test.
- Can an importer use CPSC’s Small Batch Manufacturer program to skip lab tests?
Only if the foreign factory qualifies too; lead paint and small parts still need an accepted lab.
- Are rubber or TPR soles on children’s shoes exempt from CPSC lead testing?
No: the “rubber” in 1500.91(d)(7) is a textile fiber. A sole needs total lead proof from an accepted lab, or the Small Batch route.
- What CPSC tests does a children’s toy need before I sell it in the U.S.?
A CPC on accepted-lab tests: the ASTM F963-23 sections that fit the toy, lead, lead paint, phthalates, and small parts if under 3.
eFiling and your broker
- Reference or Full PGA message set: what does my customs broker need from me?
Full: seven data elements each time. Reference: three Registry identifiers, after you certify in the Registry.
- In CPSC’s Product Registry CSV, should “Manufacturer Is New?” be Y on every row?
No: “Y” once, on the row that creates the party; every later row uses its GLN or Alternate ID with “N” or blank.
- My product’s HTS code is on CPSC’s eFiling list. Does it need a certificate?
Not automatically: the rule decides, not the code. Listed but unregulated → optional Disclaim; regulated but unlisted → certificate.
- I import blank children’s garments and print them in the U.S. Do they need a CPC and eFiling at entry?
Usually not: blanks for printing are component parts (optional Disclaim A); your CPC comes after printing, before you sell.
- My product needs no CPSC certificate. What do I tell my customs broker to file a Disclaim?
One line per invoice line: the reason, Disclaim A or B, and the intended use code with its wording.