My product needs no CPSC certificate. What do I tell my customs broker to file a Disclaim?
Give written instructions for each invoice line: what the item is, why no certificate is required, the Disclaim code (A or B) and the intended use code with CBP’s wording. The Disclaim message carries no certificate data: no Registry identifiers, labs or test dates. It is optional, but CPSC says it may improve your risk score.
What a Disclaim message contains
Two records: a commercial description of the line in English, and a PG01 record with the line number, the CPSC agency codes, the intended use code (plus a free-text description for code 980.000) and the Disclaimer code — A, “product is not regulated by this agency”, or B, “data is not required per agency guidance” CATAIR v2.5. An intended use code is required with any Disclaim CPSC code guidance, Sept. 2026. Certificate identifiers, labs and test dates are not part of it.
One line per invoice line
| Situation | Disclaim | Intended use code |
|---|---|---|
| A CPSC rule applies, but CPSC exercises enforcement discretion — e.g., adult apparel exempt under 16 CFR 1610.1(d)(1) or (d)(2) | B | 130.006, the only code allowed CPSC code guidance, Sept. 2026 |
| Within CPSC’s jurisdiction, but no rule requiring a certificate applies — e.g., adult hats and gloves | A | Among others, a 130 code other than 130.001–130.005 CPSC code guidance, Sept. 2026 |
| Component parts for manufacture or assembly, not for sale to consumers as imported | A | A 155 code, e.g., 155.001 for products for infants 0 to 18 months CATAIR v2.5 CBP Appendix R |
Add the reason and its source in plain words — for example: component parts for manufacture or assembly, not for sale to consumers as imported 16 CFR 1110.3 — and sign as importer. A Disclaim B for adult apparel rests on the fabric: the garment must be made entirely of plain-surface fabric of 2.6 oz/yd² or more, or of fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, or blends of these 16 CFR 1610.1(d). Keep the fabric sheet.
Before you claim it
- A Disclaim is not required for any shipment CPSC eFiling FAQ; filers may send no CPSC message at all, even under a flagged HTS code CBP CSMS # 69177694.
- It must be true: if a rule requiring a certificate applies and CPSC grants no enforcement discretion, the product needs a certificate CPSC code guidance, Sept. 2026.
Our free check tells you, in writing and within one U.S. business day, whether your product needs a certificate or which Disclaim type your broker may file. If a certificate is needed, it is $79 per product.
We do not file entries, clear goods or classify them.
Last reviewed: November 9, 2026 · First published: November 9, 2026 · Not legal advice.
Sources read November 9, 2026
- CBP, CPSC eFiling Implementation Guide (CATAIR) v2.5
- CPSC, eFiling Citation, Testing Exclusion, and Disclaim Guidance (Sept. 28, 2026; posted Sept. 30, 2026)
- CBP, Appendix R — Intended Use Codes for ACE (Nov. 23, 2022)
- 16 CFR 1110.3 — Definitions (importer, Product Registry)
- 16 CFR 1610.1(d) — Exemptions from testing
- CPSC, eFiling Frequently Asked Questions
- CBP CSMS # 69177694, Information from CPSC related to its PGA Message Set (eFiling) beginning July 8, 2026