CPSC disclaim codes A and B: when a line needs no certificate

CPSC eFiling has been mandatory since 8 July 2026, and entries from foreign-trade zones follow on 8 January 2027. Not every line with a CPSC-flagged tariff number needs a certificate, though. For those lines, CPSC’s PGA message set offers a disclaim: a short record that tells ACE why no certificate data is being sent.

CPSC uses two disclaim codes. Disclaim A means “product is not regulated by this agency.” Disclaim B means “data is not required per agency guidance,” and it applies only where a CPSC rule applies but CPSC is exercising enforcement discretion and does not require a certificate. Every disclaim also needs an intended use code, and Disclaim B accepts exactly one: 130.006.

The rules come from CPSC’s eFiling Citation, Testing Exclusion, and Disclaim Guidance, listed in its eFiling Document Library with a date of 30 September 2026. This guide turns that document into a decision you can make line by line.

When an entry line carries an HTS code that CPSC lists, the filer has four options:

1. Full message set. Every certificate data element goes with the line. See the data elements, field by field.
2. Reference message set. The certificate was entered in CPSC’s Product Registry beforehand, and the line carries its Certifier ID, Product ID and Version ID. See the Product Registry checklist.
3. Disclaim. No certificate is required, and the line says why, with code A or B.
4. No CPSC message. ACE will still accept the entry, but CPSC can act on any entry that lacks data it required. More on that below.

The first two are for products that need a certificate. A disclaim is for products that do not. Picking between them is a product question, not a software setting: it depends on which CPSC rules apply to the item.

CPSC’s guidance starts with one question: does a CPSC rule, ban, standard or regulation apply to this product?

Disclaim A, “product is not regulated by this agency”, covers two situations. In the first, the product falls under one of CPSC’s HTS codes and within CPSC’s jurisdiction, but no rule requiring a certificate applies. CPSC’s examples are adult hats and gloves, collectible toys intended for adults, sport helmets other than bicycle helmets, and products listed under section 15(j) in 16 CFR part 1120, other than drawstrings. In the second, the product falls under a CPSC HTS code but outside CPSC’s jurisdiction, such as medical products similar to general-use products or non-consumer industrial equipment.

Disclaim B, “data is not required per agency guidance”, is narrower. The product falls under a CPSC HTS code, is within CPSC’s jurisdiction and a rule applies, but CPSC is exercising enforcement discretion, so no certificate is required. CPSC lists only certain products, for example adult wearing apparel that claims the exemption in 16 CFR 1610.1(d)(1) or (d)(2), and household refrigerators that display an appropriate safety certification mark.

CPSC’s guidance says that a filer who submits a disclaim “must also submit an intended use code”. Which code fits depends on the branch, and the two disclaims work very differently.

For Disclaim B, the code is 130.006, “consumer product intended for people aged 13 years or older”, and no other code may be used. The reason is that the Disclaim B products are for consumers aged 13 or older. A CBP message to the trade from 14 May 2026, CSMS #68634647, flagged this restriction when it announced an updated CPSC implementation guide.

For Disclaim A, choose the code that describes the actual use. The guidance lists the families below and adds that other intended use codes may be used. On certificate lines, codes 130.001 to 130.005 are optional, and they are excluded from Disclaim A.

Every PGA message starts with a PG01 record. CBP’s general PGA Message Set CATAIR places the intended use code in positions 42–57 and a one-letter Disclaimer field, “the reason data is not being provided”, in position 80. A CPSC disclaim uses that field with A or B.

The general spec lists more letters, C to G, but those belong to other agencies or other filing paths, and CPSC’s guidance names only A and B. Use nothing else on a CPSC line unless CPSC’s current implementation guide says so.

That CPSC guide changed several times in 2026. CBP announced version 2.5 on 22 June 2026 in CSMS #69019366, which “updated scenarios under Disclaim A”, and on 28 July 2026 moved the guide into the PGA Message Set Documents section of the CATAIR (CSMS #69368723). Before you rely on a cached copy, check that your software uses the current one.

The two are easy to mix up. A testing exclusion code goes on a certificate. CPSC says these codes are used only when a certificate is required for another rule. One example is a rule-specific exemption on a product that still has to be certified to a different rule.

A disclaim replaces the certificate. If no rule requires a certificate at all, CPSC’s guidance says a disclaim may be submitted instead. So the test is simple: if at least one rule still needs certifying, file the certificate and add the exclusion codes. If none does, consider a disclaim. For which certificate a regulated product needs, see CPC vs GCC.

In CBP’s general PGA spec, disclaimer codes are generally not allowed when an HTS code is flagged “must be” provided, although some agencies make exceptions. CPSC made one. On 8 July 2026, CSMS #69177694 said CPSC is not asking CBP to reject entries for missing CPSC data, and that filers may send no CPSC message even when the HTS code is flagged CP1 or CP2.

A follow-up on 29 July 2026, CSMS #69382435, confirmed there will be no CBP reject for missing or incomplete CPSC data, as long as the message follows the CATAIR format. CPSC may still reply with its own message reviewing the data, which can reject it. It also “may perform enforcement actions on any entry that does not have eFiling data attached when required.”

So a missing message does not stop the entry, but it does not make a regulated product exempt either. A disclaim with the right code records that a decision was made. Silence records nothing.

Most disputes about disclaims come from deciding at transmission time. Deciding per SKU, before the goods ship, works better.

For brokers who want importer data in a consistent format before it reaches the ABI screen, our page for customs brokers explains how we prepare SKU-level handoff sheets, and how it works shows the steps.

A Quick Check reviews up to 10 SKUs against your certificates and test reports and shows which fields are complete, which are missing and the source page for each. $290, next business day. For a full product list, the Certificate Preflight prepares a Product Registry file and a broker handoff sheet for 25 SKUs. See all services.