CPSC eFiling Requirements Took Effect, but CBP Still Accepted Incomplete Data
CBP title: Update: Information from the Consumer Product Safety Commission (CPSC) Related to CPSC’s PGA Message Set (eFiling)
What did CBP announce?
CBP announced that CPSC fully implemented its eFiling PGA message set requirements on July 8, 2026, making eFiling of CPSC certificate of compliance data mandatory. CBP said ACE would still accept entries with missing or incomplete CPSC data, without rejecting them, as long as the overall CATAIR PGA format was followed. CPSC could still review or reject the CPSC data through a separate message and pursue enforcement action when required eFiling data was missing.
What is Allied's position?
This applied to entries for CPSC-regulated products that we filed for clients. It meant CBP would not reject an entry solely for missing CPSC data, but CPSC could still reject that data later or take enforcement action. We advised clients importing CPSC-regulated goods to provide complete certificate of compliance information at the time of filing. Later CSMS messages may have changed these requirements, so clients should ask us about their specific entries.
General information, not legal advice.
What does the CBP message say?
Update to CSMS #69177694
The U.S. Consumer Product Safety Commission (CPSC) fully implemented its eFiling Partner Government Agency (PGA) message set requirements on July 8, 2026. While the eFiling of CPSC certificate of compliance data is mandatory, CPSC has, per its final rule (https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance) and guidance (https://cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ), 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).
Therefore, software developers should allow their users to submit CPSC data even if the CPSC flagging requirements are not met.
Although CBP will not reject the entry in the above scenarios (i.e., generate an SX message with a reject), CPSC may respond to trade in an SO message, with a review about the CPSC data submitted on the entry, including rejecting the CPSC data.
REMINDER: CPSC may perform enforcement actions on any entry that does not have eFiling data attached when required.
For any questions regarding this CSMS message, please contact efilingsupport@cpsc.gov (mailto:efilingsupport@cpsc.gov).