CPSC eFiling｜Reminder Note for Two Customs Announcements

On July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) officially implemented electronic filing (eFiling). Subsequently, the U.S. Customs and Border Protection (CBP) issued two consecutive CSMS notices, providing a "buffer" clarification regarding the electronic filing (eFiling) system.

1. Main Contents of the Announcement:

1)CSMS # 69177694

On July 8, 2026, CBP issued notice CSMS # 69177694, which stated that CPSC explicitly does not enforce a hard stop rule: Customs will not automatically reject clearance declarations due to the absence of CPSC PGA message set data during the customs declaration process (i.e., failure to conduct eFiling).

The notice further clarified that regardless of whether the goods' HTS codes carry CP1 or CP2 mandatory regulatory labels, it is not required to fill in the CPSC-related PGA message set data during the declaration process, and customs declaration software is not required to implement corresponding mandatory validation and interception mechanisms. However, it is encouraged that customs declaration software include pop-up prompts to inform that the product may require CPSC electronic filing compliance data.

2)CSMS # 69382435

On July 29, 2026, the U.S. Customs and Border Protection (CBP) updated announcement CSMS # 69177694 and reissued announcement CSMS # 69382435, stating the eFiling of CPSC certificate of compliance data is mandatory, CPSC has, per its final rule and guidance, determined that US Customs and Border Protections (CBP) Automated Commercial Environment (ACE) can accept entries that do not have a CPSC message set or entries where the CPSC message set is missing some CPSC data (as long as the overall CBP and Trade Automated Interface Requirements (CATAIR) PGA message set spec is followed).

The announcement further states: Although CBP will not reject the entry in the above scenarios, CPSC may respond to trade in an message, with a review about the CPSC data submitted on the entry, including rejecting the CPSC data. The announcement also issued an important reminder: CPSC may perform enforcement actions on any entry that does not have eFiling data attached when required.

2. The Risks Under a 'Non-Interception' Approach

1)Although under the current eFiling system, U.S. Customs does not forcibly intercept imported goods that fail to meet the eFiling requirements, the current so-called 'grace period' is merely intended to prevent large accumulations of goods at ports and to facilitate coordination among importers and other parties; it does not equate to an exemption from eFiling.

2)CPSC still retains the authority to review compliance and enforce the law on imported goods. For imported goods that do not meet electronic filing (eFiling) requirements, there is a full possibility of targeted high-frequency inspections later. The risk of 'post-event enforcement' cannot be ignored.

3.Compliance Recommendations Under the Announcement Policy

CPSC electronic filing (eFiling) represents a significant change in U.S. consumer product compliance. For exporting enterprises, the focus should not only be on whether customs clearance is granted, but also on incorporating electronic filing (eFiling) into the compliance review process before shipment. This is to prevent potential non-compliance that could arise if eFiling regulations are tightened, which could result in fines, seizures, and other significant losses.