I sell from outside the U.S. and ship to U.S. customers. Who has to certify and eFile?
The importer certifies and eFiles, and a foreign business can be the importer: CPSC does not require a U.S. address. The importer is the importer of record, or, for mail and de minimis imports, any party eligible to make entry. CPSC will not typically treat a U.S. consumer buying for personal use as the importer.
CPSC’s definition of importer
The importer is the importer of record eligible to make entry: an owner, purchaser or authorized customs broker. A broker acting as importer of record may name the owner, purchaser or consignee as the party responsible for the certificate data 16 CFR 1110.3. For imported products, the importer issues the certificate 16 CFR 1110.7(a), and it need not be located in the United States or list a U.S. address CPSC CPC FAQ CPSC online sellers FAQ.
For mail and de minimis imports, the importer is any party eligible to make entry — owner, purchaser, consignee or authorized broker — and CPSC will not typically treat a consumer buying for personal use as the importer 16 CFR 1110.3.
Common setups
| Your setup | Who answers |
|---|---|
| You ship DDP; you, or a broker you appoint, make entry | You, as owner and importer of record — or named by your broker as the responsible party 16 CFR 1110.3 |
| You mail parcels to U.S. buyers today | As owner, usually a party eligible to make entry: your certificate data must be in CPSC’s Product Registry before the parcel arrives 16 CFR 1110.13(a)(1) |
| You mail parcels to U.S. buyers, once Entry Type 13 is required (January 20, 2027, per CBP CBP release, Oct. 14, 2026) | The party filing the formal entry or Entry Type 13: owner, purchaser or licensed broker. A post, carrier or forwarder acting as consignee must use one 91 FR 38007 |
| A U.S. retailer or distributor buys from you and imports | That buyer, as importer. Your test reports can support its certificate, with the documents the rule lists 16 CFR 1109.5(g) |
From Jan. 5, 2027, a foreign importer of record needs CTPAT validation or a CTPAT-validated broker, Entry Type 13 included 91 FR 69977.
Low value, marketplaces, gifts
Value does not matter: there is no de minimis exemption from eFiling. Marketplace sales are commercial, even between consumers; only a non-commercial transfer, such as a gift or personal effects the sender physically held, falls outside eFiling CPSC eFiling FAQ.
What the importer owes
A certificate for each product, with every element of 16 CFR 1110.11; the data at each entry, in full or as three Product Registry identifiers — or, for mail, in the Product Registry before arrival CPSC eFiling FAQ 16 CFR 1110.13; the certificate within 24 hours when CPSC or CBP asks 16 CFR 1110.13(c); and five years of records 16 CFR 1110.17.
We prepare certificates for importers wherever they are based: the CPC or GCC, a Product Registry import file and a broker sheet, in English, all by email. $79 per product, 2 U.S. business days.
We do not act as importer of record, customs broker or U.S. agent.
Last reviewed: November 9, 2026 · First published: September 30, 2026 · Not legal advice.
Sources read November 9, 2026
- 16 CFR 1110.3 — Definitions (importer, Product Registry)
- 16 CFR 1110.7 — Who must certify
- CPSC, Children’s Product Certificate (CPC) FAQ
- CPSC, Online Sellers Safety Guide FAQs
- CBP notice, Test of the New Electronic Informal Entry Process for Mail (Entry Type 13), 91 FR 38007 (June 24, 2026)
- CBP news release, International Mail Entry Type 13 mandatory implementation date extended to Jan. 20, 2027 (Oct. 14, 2026)
- CBP interim final rule, Heightened Requirements for Foreign Importers of Record, 91 FR 69977 (Nov. 6, 2026); effective Jan. 5, 2027
- 16 CFR 1109.5 — Relying on another party’s tests or certificates (due care, documentation)
- CPSC, eFiling Frequently Asked Questions
- 16 CFR 1110.11 — Certificate content
- 16 CFR 1110.13 — Certificate availability and eFiling
- 16 CFR 1110.17 — Recordkeeping (five years)