I import blank children’s garments and print them in the U.S. Do they need a CPC and eFiling at entry?

Component part or finished product

A component part is “intended to be used in the manufacture or assembly of a finished product, and is not intended for sale to, or use by, consumers as a finished product”; a finished product is “packaged, sold, or held for sale to, or for use by, consumers” 16 CFR 1110.3. Component part certificates “are not required and should not be eFiled” 90 FR 1823, and Disclaim A “is to be used for products imported as component parts” CATAIR v2.5.

It turns on intent, so keep proof: bulk packing, print orders, a production plan. We found no CPSC text that names blank garments imported by the printer itself. Any blanks you will sell unprinted are finished products: they need a CPC and eFiling at entry.

At entry: an optional Disclaim

• A Disclaim is not required; CPSC encourages it because it may improve your risk score CPSC eFiling FAQ.
• With a Disclaim, an intended use code is required CPSC code guidance, Sept. 2026. For commercial assembly, CBP’s codes run from 155.001 (products for infants 0 to 18 months) and 155.002 (19 to 36 months) to 155.006 (13 years or older) CBP Appendix R.
• Adult garments in fabric exempt under 16 CFR 1610.1(d)(1) or (d)(2) are CPSC’s example for Disclaim B, which allows only code 130.006 CPSC code guidance, Sept. 2026.

After printing, before you sell

For a product made in the United States, the manufacturer certifies; if the garment carries another company’s brand (private label), that brand owner certifies unless you, as manufacturer, issue the certificate 16 CFR 1110.7(b). The certifier issues the certificate on or before the date the product is distributed in commerce, furnishes it to each distributor or retailer, and makes it available within 24 hours if CPSC asks 16 CFR 1110.13(a)(2), (b). There is no import to eFile.

CPSC’s own (fictitious) example CPC is a screen-printed baby bodysuit certified by a Boston screen printer: you may be able to rely on a blank supplier’s third-party component tests under 16 CFR part 1109, but “you must still issue a CPC for the finished product” CPSC example CPC. The print and any printed label then decide which tests apply.