Prepare a file for each certificate-required product: match the actual SKU, test evidence, certifier and Full or Reference eFiling handover before payment or shipment.
Before paying for a product you plan to sell in the United States, ask for more than a PDF labeled “CPC.” You need to connect the exact item you are buying to its applicable safety rules, supporting tests, responsible certifier and import filing data. A report for a similar model leaves that connection unfinished.
This CPSC import checklist is for small retailers and buyers of products that actually require a CPSC compliance certificate. Its output is a file for each SKU—your stock identifier—that your certifier and customs broker can review. It does not assume every product needs a Children's Product Certificate.
Policy checked: October 8, 2026. CPSC implemented mandatory eFiling on July 8, 2026. The Full and Reference filing discussion below concerns ordinary non-postal commercial entries. International mail has separate current CPSC instructions, and the separate implementation date for relevant Foreign Trade Zone entries is January 8, 2027. Have the filer confirm the actual entry route.
Start with the product, not the seller's certificate label
Give the importer or a product-compliance professional the intended use, intended age group, materials, exact model and photographs. Ask which CPSC rules apply and whether certification is required. CPSC's applicability resources help with this first decision; a marketplace category or seller's “export quality” description cannot make it for you.
- Children's product: a product designed or intended primarily for children aged 12 or younger needs a CPC when applicable children's product safety rules require certification. Supporting third-party testing generally needs a CPSC-accepted laboratory; specific testing exclusions must be checked, not assumed.
- General-use product: a regulated non-children's product may need a General Certificate of Conformity, or GCC, based on product testing or a reasonable testing program. A CPSC-accepted third-party laboratory is not universally required. See the GCC requirements.
- No CPSC certificate requirement identified: record the product-specific reason and who checked it. This is not approval under other U.S. laws, nor permission to ignore a recall, ban, labeling rule or transport restriction.
Buying for personal enjoyment does not automatically remove a commercial online purchase from eFiling scope. At the same time, CPSC does not typically treat an ordinary personal-use consumer as the party responsible for issuing the certificate. Low shipment value does not exempt a product that requires certification from eFiling. A noncommercial gift transfer and a sample imported only for testing have specific conditions; neither label is a shortcut for resale stock. If that distinction affects your order, have the importer and broker check it before payment against the current eFiling FAQ.
Build a dossier that follows the actual SKU
Use a separate working row for every purchased SKU or variant so nothing gets lost. This is a recordkeeping method, not a claim that every color automatically requires a separate test. The certifier must determine the product and variant coverage.
Under current 16 CFR part 1110, a finished-product certificate describes one product and needs a suitable unique identifier and enough detail to match it. Record the certifier's required attestation as well as the underlying information; an old certificate layout alone may be incomplete.
| Part of the working file | What to match or obtain |
|---|---|
| Product identity | Actual SKU/model and identifier type, item description, intended age/use, variant photos, packaging and invoice or packing-list references |
| Applicable rules | Each applicable rule and its filing citation code, linked to the test supporting it; any claimed testing exclusion with its basis |
| Certificate and certifier | CPC or GCC for this product; responsible certifier's name, full address, email and telephone; required attestation |
| Production | Manufacturing date, at least month and year, plus actual factory name, full location and contact details—not just the seller's office |
| Testing | Most recent relevant test date, report and sample identity; full details for each testing party, matched to the rules it tested |
| Records contact | Name or staffed position, full address, email and telephone of the person maintaining supporting records |
| Filing handover | Chosen Full or Reference method, current certificate version, responsible entry filer and shipment/entry-line mapping |
These are document checks, not boxes to tick from memory. If a supplier gives you a report without the model, factory or tested materials, ask for the missing connection before treating it as evidence. Keep the certificate in English; children's-product supporting test reports also need to be in English under CPSC's CPC guidance.
The factory can provide production information and test records. The responsible importer/certifier must confirm the basis for certification, even where another party helps prepare the file. A laboratory tests; it does not replace the party legally responsible for the certificate. Have the broker identify that party for your actual entry arrangement. If the shipping contract leaves importer roles unclear, resolve that using the DDP/DAP responsibility checklist before handing over this file.
A toy report with the wrong variant: pause the order
Suppose a small U.S. shop wants to buy blue and red plastic stacking toys for young children. This is a hypothetical document check, not a real YDA order or a complete toy-compliance assessment.
The seller supplies a report showing a blue sample, but the red version uses another coating. Do not quietly copy the blue SKU's evidence into the red row. Ask the certifier and laboratory whether the changed material is covered, whether further testing is needed and which certificate version will describe the goods supplied. Also compare the manufacturer, production details, intended age and packaging with the actual order.
Look up the laboratory in CPSC's accepted-laboratory directory, then check its acceptance for the particular rules involved. A laboratory in China can be accepted; location alone does not establish validity. A CE mark or an unrelated China test report does not establish that this U.S. product file is complete.
If the supplier cannot explain the mismatch or provide usable supporting records, keep that SKU out of the shipment approval. Consider a different product or supplier. A small order quantity and a warehouse photograph do not resolve missing safety evidence.
Hand the file to the filer: Full and Reference do different jobs
ACE is CBP's electronic import system. A PGA Message Set is the agency-specific data sent with the customs entry. Agree with the broker on which method they will use; CPSC's Quick Start Guide explains the two paths.
Full: send the required data with the entry
Provide the filer with the product identifier, applicable citation codes, manufacturing date and place, relevant test date, testing-party information and records contact. These are the seven eFiling data groups described by CPSC—not a substitute for all current certificate-content requirements. The filer must handle the current message format, certification details, attestation and any applicable testing exclusions. Full filing does not require a Product Registry account.
Reference: point the entry to the right stored certificate
After the correct certificate data are entered and certified in the Product Registry, give the broker all three identifiers: Certifier ID, Product ID and Version ID. Verify the primary product identifier and version against the approved SKU file. Reusing a reference is appropriate only when the certificate details still cover the actual goods; changed evidence or manufacturing details need review and a current version.
The Product Registry FAQ makes the handover explicit: the registry does not automatically transmit to ACE. “Uploaded to the registry” does not mean “filed with this entry,” and neither means “CPSC approved the product.” Ask the filer to confirm the entry-line mapping and transmission status, and keep their response with the SKU dossier.
Use the warehouse check to catch differences, not to certify safety
For a 1688 bulk order, request the file for the exact manufacturer and production variant before paying a deposit. For a Taobao or Pinduoduo retail listing, first ask whether the seller can obtain that evidence from the actual manufacturer; a listing screenshot alone is not enough. After receipt, compare visible model numbers, labels and packaging with the approved file. Before dispatch, send any discrepancies back to the certifier rather than editing a certificate to fit the parcel.
YDA Express may assist with seller communication, receiving records and agreed photographs or visible checks. YDA does not issue your CPC/GCC, conduct professional safety testing, act as your regulatory approval authority or guarantee acceptance by customs or CPSC. Confirm any proposed support in advance. Eligible ordinary goods may have up to 180 days of free storage, subject to warehouse acceptance and the current storage policy; this does not make restricted goods acceptable or extend a seller's return deadline.
Keep recalled, banned, unidentified or insufficiently documented products on hold. Battery or liquid transport acceptance, where relevant, is a separate review from this certificate file. When you are ready to request transport for a larger commercial shipment, use the U.S. shipment quote checklist.
This file does not calculate duties, establish customs value or replace an import invoice. Keep the tax and charge review separate from the product-safety decision.
Before paying, ask who will resolve each missing field. Before dispatch, have the importer and filer recheck current CPSC rules, applicable exclusions, certificate versions and entry instructions. Product rules, import procedures and carrier conditions can change; the check date above is not a future approval. Under current part 1110, the certifier must retain certificates and supporting records for at least five years from certificate creation; check any additional product-specific retention obligations as well.
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