My product’s HTS code is on CPSC’s eFiling list. Does it need a certificate?
Not automatically. CPSC’s list of about 600 HTS codes flags goods likely to be regulated, and it is not complete. What decides is whether a CPSC rule, ban or standard applies. If none does, no certificate is needed and your broker may file an optional Disclaim; if one does, you need a certificate even if your code is unlisted.
What the list is
CPSC’s October 2026 list holds about 600 HTS codes that likely include a product subject to a mandatory standard, or are otherwise deemed high-risk. In this edition, each code carries a flag: CP2, “CPSC Certificate Related Data is Required”, or CP1, “May be Needed”. CPSC warns that the list does not cover every code where an electronic certificate may be required, and that the importer is responsible for eFiling whenever a certificate is required CPSC HTS list, Oct. 2026. The eFiling FAQ says the same of its code lists: they are not all-encompassing CPSC eFiling FAQ.
Three cases
| Your product | What is filed |
|---|---|
| A CPSC rule applies, whether or not the code is listed | A certificate, eFiled at entry 16 CFR 1110.13(a)(1), as a Full or Reference message set CPSC eFiling FAQ |
| Listed code, but no rule requiring a certificate applies — CPSC’s examples: adult hats and gloves, collectible toys intended for adults, sport helmets other than bicycle helmets | Nothing required; optional Disclaim A CPSC code guidance, Sept. 2026 |
| A rule applies, but CPSC exercises enforcement discretion — for example adult apparel in fabrics exempt from flammability testing | Nothing required; optional Disclaim B CPSC code guidance, Sept. 2026 81 FR 12587 |
Why file an optional Disclaim
Disclaim messages are not required for any shipment, low-value ones included, but CPSC encourages them because they may improve your risk score CPSC eFiling FAQ CPSC HTS list, Oct. 2026. A flag does not block an entry either: CPSC told brokers’ software providers that filers are allowed to send no CPSC message even if a code is flagged CP1 or CP2 CBP CSMS # 69177694. That is about the entry system, not your duty: if a rule applies, the certificate is still eFiled. Each Disclaim carries an intended use code; for Disclaim B, the only code allowed is 130.006, consumer products for people aged 13 or older CPSC code guidance, Sept. 2026.
Changing the code does not change the answer
The HTS number comes from the product’s tariff classification; CPSC sends importers to CBP and their trade partners for it CPSC eFiling FAQ. A code picked to stay off the list removes no certificate requirement: the rule decides, not the code.
Our free check tells you, in writing and within one U.S. business day, which of the three cases your product is in: the rules that apply, or the Disclaim type your broker may file. If a certificate is needed, it is $79 per product.
Last reviewed: October 5, 2026 · First published: September 30, 2026 · Not legal advice.
Sources read October 5, 2026
- CPSC, Guidance and HTS List for eFiling, October 2026 (Excel, posted Sept. 30, 2026)
- CPSC, eFiling Frequently Asked Questions
- 16 CFR 1110.13 — Certificate availability and eFiling
- CPSC, eFiling Citation, Testing Exclusion, and Disclaim Guidance (Sept. 28, 2026; posted Sept. 30, 2026)
- CPSC policy statement on adult wearing apparel exempt from testing, 81 FR 12587
- CBP CSMS # 69177694, Information from CPSC related to its PGA Message Set (eFiling) beginning July 8, 2026