As a reminder, the U.S. Consumer Product Safety Commission (CPSC) is transitioning from voluntary to mandatory eFiling of Certificates of Compliance for most regulated consumer products beginning July 8.
While eFiling does not change the applicable consumer product safety requirements for imported products, it introduces a new process by which the required product certificate information must be transmitted to both CPSC and U.S. Customs and Border Protection (CBP).
Specifically, eFiling requires importers to electronically submit certificate data through CBP’s Automated Commercial Environment (ACE) using the Partner Government Agency (PGA) Message Set. Proper eFiling is the importer’s responsibility.
Importers may transmit certificate data using one of two options:
- The Full PGA Message Set is the standard method for importers who import a limited amount of regulated goods, or whose shipments are covered by different product certificates. The importer provides their broker with the full product certificate for the imported product, and the broker files it in the CPSC PGA Message Set.
- The Reference PGA Message Set is recommended for importers who repeatedly import regulated consumer products covered by the same product certificate. The certificate data can be uploaded in advance and assigned a reference number. The importer or broker can then simply transmit the reference number with each entry instead of re-submitting the full certificate data.
Please contact us if you would like assistance preparing for eFiling or reviewing your products for applicable consumer product safety requirements.
For further information, please contact Gail Cumins at gcumins@spcblaw.com, Alli Baron at abaron@spcblaw.com or call us at 212-425-0055.
