CPSC eFiling data elements, explained field by field

Since 8 July 2026, importers of most CPSC-regulated products must file certificate data electronically with each US entry. The data elements are the contents of your GCC or CPC, broken into fields that CBP’s ACE system can read: product identifiers, the rules cited, the parties, and the dates and places of manufacture and testing.

Your broker files them in one of two ways: the full message set, with every field on every entry, or a reference to a record you certified in CPSC’s Product Registry. Either way, the values have to match your certificate and test reports exactly. This guide walks through every field, what to enter, where to find it and which ACE record carries it.

The fields are not new paperwork. They come from the seven content requirements for a certificate in 16 CFR 1110.11, as updated by the Certificates of Compliance final rule. CPSC says eFiling “creates no new testing, certification, or compliance obligations”: it changes how existing certificate data is sent.

The record names below, such as PG01 and PG19, come from CPSC’s eFiling implementation guide for ACE, part of the CBP and Trade Automated Interface Requirements (CATAIR). CPSC revises that guide from time to time, and the current version is in its eFiling Document Library, so treat record codes as a map for talking to your broker, not as a filing spec.

This is the working list. Every row is a value someone has to look up, check and hand to your broker or enter in the Registry.

Two fields cause most of the questions. Product identification needs at least one unique identifier and a description that ties the certificate to the product; “assorted” or “various” does not. Date of last testing must be the most recent test the certificate relies on, which is not always the date the certificate was signed. See 7 certificate data mistakes for the gaps we find most often.

Record PG19 names the companies and people behind the certificate. Each one is a separate line with a role code, and most need a full address, phone number and email.

For a children’s product, the lab must be accepted by CPSC for the tests cited, and its 4-digit lab ID goes in the ITL line. The certifier and records contact lines are needed only when they are someone other than the importer of record. Not sure which certificate you need? Read CPC vs GCC.

The certificate data is the same on both routes. What changes is where it lives and what travels with each entry.

Under the final rule, products imported by international mail must use the Product Registry, with the data entered before the shipment arrives, and low-value shipments are not exempt from filing. For a list of what to collect before you open a Registry record, see our Product Registry checklist.

Testing exclusions. If a statutory or regulatory exclusion applies, for example for certain materials, the certificate identifies the exclusion in place of the test date and place for that rule, as 16 CFR 1110.11(c) requires. In the message set this is the NOL role, with an exclusion code.

Disclaims. The message set also has a disclaim option for lines that need no CPSC certificate. In the implementation guide, code A covers products CPSC does not require certificate data for, and code B covers data CPSC does not require under its own guidance. Whether you need to send a disclaim for a given line is a question for your broker and CPSC’s eFiling FAQ: do not use one to skip data a regulated product needs.

Foreign trade zones. Products entered from a foreign trade zone for consumption or warehousing follow from 8 January 2027.

A CBP message to the trade on 29 July 2026, CSMS #69382435, clarified what ACE does with CPSC data. ACE can accept an entry with no CPSC message set, or with some CPSC data missing, as long as the overall format is followed, and CBP will not reject the entry for that alone. The same message says eFiling is mandatory, that CPSC may reply to the filer and reject the CPSC data, and that CPSC “may perform enforcement actions on any entry that does not have eFiling data attached when required.”

In practice, an accepted entry only means the message was readable. CPSC uses the filed data to decide which shipments to look at, so missing or mismatched fields raise the odds of a hold or an exam, and of a slower release while you find the right document.

The fastest way to file cleanly is one data sheet per SKU, built before the goods ship and shared with your broker.

1. List every SKU on the next shipment and mark which ones are covered by a CPSC rule.
2. Collect the four sources above for each covered SKU: test report, supplier and purchase-order details, packaging data and your own records.
3. Fill each field from its source, and note the document and page it came from, so anyone can check it.
4. Check the matches: the model on the certificate, the test report and the invoice should be the same, and every rule cited should appear in the test report.
5. Choose the route with your broker: full message set or Registry reference, and map every reference ID to its SKUs.
6. Keep the records for five years from the date the certificate was created.

A Quick Check reviews up to 10 SKUs against your certificates and test reports and shows which fields are complete, which are missing or inconsistent, and the source page for each. $290, next business day. Need the full data sheet? The Certificate Preflight prepares a Product Registry file and a broker handoff sheet for 25 SKUs.