PortCert
Questions · Deadlines and shipping

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 setupWho answers
You ship DDP; you, or a broker you appoint, make entryYou, 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 todayAs 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 importsThat 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.

How PortCert handles this

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.