Executive Summary The Consumer Product Safety Commission has issued guidance, dated July 2026, to help importers and customs brokers comply with the CPSC’s eFiling requirement for mail shipments using the new Entry Type 13. Beginning October 22, 2026, the CPSC will require eFiled certificates for mail shipments via a full or reference message set in the Automated Commercial Environment. This requirement applies to all CPSC-regulated consumer products and substances that require certification, including de minimis shipments. The importer—defined as an owner, purchaser, consignee, or authorized customs broker—is responsible for eFiling the certificate whenever one is required. With the Entry Type 13 test launching September 22 and the CPSC eFiling mandate taking full effect for mail shipments on October 22, logistics providers and importers have a narrow window to prepare.

CPSC eFiling for Mail Shipments: October 22 Deadline Approaches

(CPSC邮寄货物电子申报：10月22日截止日期临近)

1 · The CPSC eFiling Program: A Brief Overview

What Is CPSC eFiling?

The CPSC’s eFiling program requires importers to electronically file certificate of compliance data elements at the time of filing an entry. The program applies to imports of all CPSC-regulated consumer products and substances that require certification.

The mandate became effective for most entry types on July 8, 2026. However, international mail shipments—which historically moved through a separate, less automated process—were given a slightly longer runway.

The Six Required Data Elements

Under the CPSC’s eFiling program, importers must electronically file the following six data elements:

These data elements must be transmitted via the PGA Message Set in ACE—the same mechanism used for other Partner Government Agency requirements.

Three Ways to Satisfy the Requirement: importers are not limited to submitting all six data elements individually on every entry. CPSC’s eFiling framework generally accepts any of the following: (1) the full set of certificate data elements transmitted as a Full Message Set; (2) a Product Registry ID referencing certificate data already on file in the CPSC Product Registry, transmitted as a Reference Message Set; or (3) in certain circumstances, a copy of the underlying General Certificate of Conformity (GCC) or Children’s Product Certificate (CPC) itself. For importers or brokers handling repeat shipments of the same products, registering products in advance and filing Reference Message Sets is generally the more efficient path, since it avoids re-transmitting the same six data elements on every entry.

The De Minimis Exception Is Gone

Importantly, the eFiling requirement applies regardless of shipment value. Shipments that previously qualified for duty-free de minimis treatment under Section 321 are not exempt from CPSC eFiling. This is a critical point for e-commerce sellers and logistics providers handling small parcels: even low-value shipments of regulated consumer products must now have eFiled certificates.

2 · Entry Type 13: The New ACE Mechanism for Mail

What Is Entry Type 13?

Entry Type 13—“Informal Mail Entry”—is a new electronic entry type being introduced by CBP specifically for international mail shipments valued at $2,500 or less. It is designed to replace the manual Excel spreadsheet submission process that took effect in July 2026 as an interim measure following the suspension of the de minimis exemption.

The Launch Timeline

The Entry Type 13 test is voluntary—filers may continue using the interim spreadsheet process if they choose. However, the CPSC eFiling requirement for mail shipments is mandatory beginning October 22, regardless of which entry mechanism is used.

The CPSC Guidance

The CPSC’s guidance document clarifies how the eFiling requirement applies specifically to mail shipments using Entry Type 13. The guidance can be accessed directly on the CPSC website.

Key points from the guidance:

• The importer is responsible for eFiling a certificate whenever one is required
• For purposes of this requirement, the importer is defined as a party eligible to make entry pursuant to CBP statutes and regulations—including an owner, purchaser, consignee, or authorized customs broker
• eFiled certificates must be transmitted via a full or reference message set in ACE

3 · What This Means for Logistics Providers

The E-Commerce Impact

The combination of the de minimis suspension, Entry Type 13, and CPSC eFiling creates a triple compliance burden for e-commerce sellers and the logistics providers that serve them:

1. De minimis is suspended: Low-value shipments must now be formally entered
2. Entry Type 13 is coming: The manual spreadsheet process is being replaced (or supplemented) by electronic filing in ACE
3. CPSC eFiling is mandatory: Even low-value shipments of regulated consumer products must have eFiled certificates

For logistics providers handling high volumes of small parcels from international sellers, the operational impact is significant. Every shipment of CPSC-regulated consumer products—toys, electronics, clothing, furniture, and hundreds of other categories—must now have certificate data on file before the shipment can be released.

The PGA Message Set Integration

CPSC eFiling data must be transmitted through the PGA Message Set in ACE. This is the same mechanism used for FDA, USDA, FWS, and other Partner Government Agency requirements. Logistics providers that already handle PGA-regulated goods will have systems in place—but those that primarily handle e-commerce small parcels may need to build new capabilities.

The “No Denial” Policy—For Now

Currently, CPSC does not intend to direct CBP to deny entry solely because a party did not electronically submit certificate data. However, this policy could change, and even without denial, shipments without proper eFiling may face:

• Delays in release
• Increased examinations
• Penalties for non-compliance
• Detentions and potential forced returns

The Importer Responsibility

The CPSC guidance makes clear that the importer is responsible for eFiling the certificate. For mail shipments, the importer may be the owner, purchaser, consignee, or authorized customs broker. This means:

• Brokers that file entries on behalf of mail shipment importers may bear the responsibility for eFiling
• Logistics providers that act as intermediaries may need to ensure that the responsible party has eFiled before release
• Foreign sellers shipping directly to U.S. consumers may need to engage a broker or agent to handle eFiling

4 · The Data Challenge: What Importers Must Have Ready

The Six Data Elements—In Practice

While the six data elements may seem straightforward, obtaining them can be challenging—particularly for importers with limited visibility into their supply chains.

1. Identification of the finished product: This requires precise product identification—not just a generic description. GTIN, UPC, or SKU numbers may be needed.

2. The party certifying compliance: The certifying party must be identified by name and contact information. This is typically the importer, but may be the manufacturer or another party.

3. Each consumer product safety rule: Importers must know which CPSC rules apply to their products. There are approximately 600 HTSUS numbers flagged for CPSC eFiling requirements.

4. Date and place of manufacture: This requires manufacturing traceability—not always available for products sourced through complex supply chains.

5. When and where tested: Importers must know when and where compliance testing was performed, and maintain records of those tests.

6. Contact information for test record custodian: The person or entity maintaining test records must be identified with complete contact information.

The Product Registry Requirement

For mail shipments, certificate data must be logged in the CPSC Product Registry prior to cargo arrival in the U.S. . This adds an additional layer of timing complexity: the data must be submitted before the shipment arrives, not at the time of entry.

The Consequences of Incomplete Data

Without complete and accurate data, shipments may be:

• Delayed while the importer or broker scrambles to obtain missing information
• Examined by CBP or CPSC, leading to further delays
• Detained pending verification
• Subject to penalties for non-compliance

5 · What Importers and Logistics Providers Must Do Now

1. Identify CPSC-Regulated Products in Your Supply Chain

Not all products require CPSC certification. Importers should:

• Review their product portfolio against the approximately 600 HTSUS numbers flagged for CPSC eFiling
• Identify which products are subject to CPSC rules
• Determine whether those products require certificates of compliance

2. Obtain the Six Data Elements

For each CPSC-regulated product, importers must obtain and verify the six required data elements:

• Product identification
• Certifying party
• Applicable safety rules
• Date and place of manufacture
• Date and place of testing
• Test record custodian contact information

3. Register Products in the CPSC Product Registry

For mail shipments, certificate data must be logged in the CPSC Product Registry before the shipment arrives. Importers should:

• Establish CPSC Product Registry accounts
• Register products in advance
• Ensure data is current and accurate

4. Prepare for Entry Type 13

With Entry Type 13 launching in ACE Production on September 22, 2026, logistics providers should:

• Test the new entry type in the ACE Certification environment
• Train staff on Entry Type 13 procedures
• Prepare for the transition from the spreadsheet-based interim process

5. Meet the October 22 Deadline

The CPSC eFiling requirement for mail shipments becomes mandatory on October 22, 2026. Importers and logistics providers should:

• Ensure systems are capable of transmitting eFiling data via ACE
• Confirm that suppliers can provide the required data elements
• Develop contingency plans for shipments that may not have complete data

6. Consider the Broader Compliance Landscape

CPSC eFiling is just one part of a broader compliance shift. Importers and logistics providers should also consider:

• CBP’s heightened import disclosure ANPRM (comments due December 1)
• De minimis suspension and the new low-value entry procedures
• Other PGA requirements (FDA, USDA, FWS, etc.)

6 · Conclusion: A Critical Deadline Approaches

The CPSC’s guidance on eFiling for mail shipments, combined with the launch of Entry Type 13, represents a significant shift in how CPSC-regulated consumer products will be processed when arriving via international mail.

Key Takeaways

The Bottom Line

The October 22 deadline is fast approaching. Importers and logistics providers that handle CPSC-regulated consumer products arriving via international mail must act now to:

1. Identify which products are subject to CPSC eFiling
2. Obtain the six required data elements
3. Register products in the CPSC Product Registry
4. Prepare for Entry Type 13
5. Meet the October 22 deadline

The message is clear: CPSC eFiling for mail shipments is coming—and it applies to everyone, regardless of shipment value.

This analysis reflects the CPSC’s “Guidance for Mail Shipments on Electronic Filing (eFiling) of Certificates of Compliance,” dated July 2026, and related Entry Type 13 developments. The CPSC guidance document is available at www.cpsc.gov. Organizations handling CPSC-regulated consumer products should consult with customs brokers and trade compliance professionals for guidance tailored to their specific products and operations.