---
content_id: international-shipping-cpsc-efiling-import-certificate
canonical_url: https://11tracking.com/international-shipping/cpsc-efiling-import-certificate/
title: "CPSC eFiling or Certificate Request for a U.S. Import: What the Shipment
  Action Means"
meta_description: A CPSC certificate or PGA data request is not proof of
  detention or seizure. Classify the shipment-specific CPSC message, separate
  certifier from filer or broker roles, and check whether CBP cargo release is
  still unresolved.
language: en
published_at: 2026-08-19
last_reviewed: 2026-08-18
carrier_scope:
  - U.S. Consumer Product Safety Commission certificate/eFiling and
    import-review processes
  - FedEx, UPS, and DHL Express only where their current U.S.-bound CPSC intake
    or brokerage workflows are expressly identified as carrier-specific examples
  - Imported-by-mail treatment only where 16 CFR Part 1110 expressly provides a
    separate lane
jurisdiction_scope:
  - United States
---


# CPSC eFiling or Certificate Request for a U.S. Import: What the Shipment Action Means

If a carrier or customs broker asks for **CPSC certificate information, Full PGA data, or Reference PGA identifiers**, the shipment has a CPSC-specific data dependency in its U.S. import workflow. That request does **not** by itself mean the product failed testing, CPSC formally detained it, CBP seized it, or customs permanently rejected it.

CPSC eFiling is the electronic transmission of certificate information for imported products that are already subject to a CPSC certification requirement. The mandatory eFiling implementation took effect on **July 8, 2026** for the main import scope. CPSC says the change does not itself create new testing, certification, or product-compliance obligations.

This guide applies only when you have a **shipment-specific CPSC object**: a carrier or broker request for CPSC certificate/PGA data, a missing-PGA warning, a CPSC import-review message such as **Under Review**, **Intensive Exam**, **Intensive Exam with Documents Required**, **Hold Intact**, or **Hold Intact with Documents Review**, or a verified state in the CPSC Import Shipment Tracking Tool.

If there is no verified CPSC-specific object and the package is simply delayed at customs, use [Package Stuck in Customs](/package-problems/package-stuck-in-customs/) instead.

## Why your carrier or broker may be asking for CPSC information

The request usually means the party filing or managing the U.S. entry needs CPSC certificate data for the shipment workflow. It does not tell you, by itself, who legally created the underlying certificate, who owns the test information, whether CPSC has selected the shipment for examination, or whether CBP has released the cargo.

The first distinction is therefore:

**certificate or compliance obligation ≠ electronic transmission or eFiling obligation**

A product can have an existing CPSC certification obligation, while eFiling governs how required certificate information is transmitted for the import entry. Conversely, the fact that an item is a consumer product does not prove that it requires CPSC certification. Under [16 CFR Part 1110](https://www.ecfr.gov/current/title-16/chapter-II/subchapter-B/part-1110), the eFiling rule applies to imported finished products that are subject to a CPSC certification requirement.

If your real question is whether a particular toy, jewelry item, appliance, used item, handmade product, or other product legally requires certification, this page cannot decide that for you. Use current [CPSC certificate and product-compliance guidance](https://www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates) and the product-specific CPSC resources that apply to the item.

## Certificate information, Full PGA, Reference PGA, and Product Registry

At a classifier level, there are two common eFiling patterns:

- **Full PGA:** the required certificate data are supplied for transmission with the entry.
- **Reference PGA:** certificate identifiers point to certificate data stored in the CPSC Product Registry.

Those are transmission methods. They do not change the underlying rule that the certificate information must be truthful and tied to the actual product and responsible certifier.

The [CPSC Product Registry](https://www.cpsc.gov/eFiling-CPSC-Product-Registry) is a separate certificate-data repository. CPSC expressly says the Registry does not communicate with ACE by itself.

Keep these states separate:

**Product Registry record exists ≠ PGA message transmitted ≠ ACE entry accepted ≠ cargo released**

Registering a product is therefore not proof that customs has received the shipment's PGA message or that the package has been released.

### What if the package is low value?

A low shipment value does not, by itself, create a CPSC eFiling exemption. Current [CPSC eFiling guidance](https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) says that, where certification is required, eFiling applies regardless of shipment value and there is no Section 321/de minimis value exemption from the CPSC eFiling requirement.

That is a narrow CPSC statement. It does **not** determine duty-free treatment, tariff liability, entry eligibility, or any other low-value customs rule.

## Who is actually responsible: certifier, filer, broker, recipient, and government actors

Do not infer responsibility from the name printed on the package or from the carrier logo. Several roles can exist in the same import.

| Role | What the role means here | What it does not automatically mean |
| --- | --- | --- |
| **Data owner** | The party that has the truthful product, certificate, manufacturer, testing, and rule information needed for the shipment. | It is not automatically the filer or physical recipient. |
| **Compliance / certifier actor** | The party responsible for the certificate under the actual CPSC import structure. | It is not automatically the carrier or customs broker. |
| **Filer / broker** | The party that transmits entry and PGA information or performs the authorized brokerage task. | Transmitting data does not automatically make the broker the finished-product certifier. |
| **CPSC** | The product-safety agency that reviews and enforces CPSC requirements. | CPSC is not CBP and a CPSC review message is not a CBP seizure notice. |
| **CBP** | The agency that controls the customs entry and cargo-release process and can act under its own customs authority. | A CPSC message does not substitute for CBP's cargo-release state. |
| **Carrier** | The transport company and, in some cases, the brokerage or data-intake actor. | The carrier does not automatically own the underlying certificate obligation. |
| **Physical custodian** | The carrier, warehouse, examination station, government facility, or other party that physically has the goods at that moment. | Physical possession does not itself identify the compliance actor. |

CPSC's current rule also preserves an important personal-use qualification: CPSC says it will **not typically** consider a consumer purchasing or receiving a product for personal use or enjoyment to be the importer responsible for certification. That is not an absolute statement that a recipient can never have an import role. The actual entry structure still matters.

A broker-as-Importer-of-Record case also requires care. Current CPSC rules allow an authorized broker acting as IOR, in specified circumstances, to identify the owner, purchaser, or consignee that authorized entry as the responsible CPSC compliance party. The correct question is therefore **who is responsible under this entry**, not simply “whose name appears as IOR?”

## Match the exact CPSC shipment object before deciding what it means

CPSC review messages are evidence objects, not a universal chronological ladder. One message should not be converted into a stronger state that the message does not establish.

| Request or status | What it confirms | What it does not confirm | Correct next actor |
| --- | --- | --- | --- |
| **Carrier or broker asks for CPSC certificate/PGA data** | The shipment workflow has a CPSC-specific data dependency. | Failed testing, formal detention, CBP seizure, or permanent rejection. | Identify the actual certifier/data owner and use the authenticated carrier or broker intake route. |
| **Missing-PGA warning** | The expected CPSC PGA data were not supplied in the entry as expected. | Automatic ACE rejection, automatic hold, or harmlessness. | Filer/broker plus the party that owns the truthful certificate data. |
| **Under Review** | CPSC is electronically reviewing the entry. | A physical stop, formal detention, seizure, or final cargo release. | Broker/filer for the entry message; CPSC import resources for the agency meaning. |
| **Intensive Exam** | CPSC is seeking an intensive examination of the shipment. | That CBP has necessarily approved the request or that a formal detention exists. | Broker/filer should verify whether CBP concurred and what current CBP hold message exists. |
| **Intensive Exam with Documents Required** | CPSC is seeking an intensive examination and additional records for its review. | A final admissibility decision, formal detention, or seizure. | Broker/filer and the truthful data owner; verify the resulting CBP action separately. |
| **Hold Intact** | CPSC has signaled an examination-related hold-intact instruction in its import messaging. | That CPSC physically possesses the goods, that formal CPSC detention has begun, or that CBP seized the shipment. | Broker/filer should inspect the current CPSC/CBP entry messaging and any CPSC Form 354 made available for the entry. |
| **Hold Intact with Documents Review** | CPSC has combined a hold-intact examination state with a request for records needed for review. | A universal custody state, formal detention, seizure, or final outcome. | Broker/filer and the party that owns the requested truthful records. |
| **May Proceed / 1USG** | A CPSC/PGA paperwork-completion message has been issued. | CBP cargo release. | Verify the separate ACE cargo-release state; do not substitute 1USG for 1C. |
| **CPSC shipment-tracker state** | The CPSC public tool is reporting a CPSC review status for the queried entry. | An official CPSC release or CBP release. | Use the broker/filer or official entry system for release; use CPSC for CPSC-specific review questions. |

CPSC's current [Import Resources](https://www.cpsc.gov/Imports) and its June 2026 [1USG messaging guidance](https://www.cpsc.gov/s3fs-public/2WayMessagingforCPSCGuidanceDocumentJune2026FINAL.pdf) control the federal meaning of these messages. A carrier's normalized wording should not be used to invent a stronger government status.

## A missing-PGA warning is not an automatic rejection — and it is not harmless

Current CPSC guidance says CPSC does **not initially intend** ACE to reject an entry solely because Full or Reference PGA certificate data are missing. CPSC describes the initial missing-data response as a **warning rather than a reject**.

That does not remove the underlying certificate obligation. CPSC also says certificate data can affect risk scoring, and missing or inaccurate compliance information does not prevent CPSC from requesting information, examining products, taking enforcement action, or asking CBP to seize noncompliant products where legally appropriate.

So both shortcuts are wrong:

- **“The data are missing, therefore the package is automatically seized.”** Not established.
- **“The data are missing, therefore nothing can happen.”** Also not established.

The correct next step is to identify whether the request is for missing transmission data, a certificate-content problem, or a stronger CPSC review/examination object.

## Under Review does not by itself mean the package is physically stopped

CPSC defines **Under Review** as electronic review of an entry of interest. Its current guidance says cargo can continue through the port after that message unless CPSC requests an intensive examination and **CBP concurs**, or CBP or another Partner Government Agency has an independent reason to examine the cargo.

That actor transition matters:

**CPSC intensive-exam request + CBP concurrence = a materially stronger cargo-hold/examination state**

Do not collapse the CPSC request and CBP's action into one event.

The same caution applies to **Hold Intact** and **Hold Intact with Documents Review**. Those are real CPSC examination-related messages, but they should not be rewritten as “formal detention,” “seizure,” or a universal physical-custody state unless a stronger official object establishes that fact.

## CPSC May Proceed or 1USG is not CBP cargo release

CPSC's 1USG guidance makes a retrieval-critical distinction:

**CPSC/PGA 1USG paperwork completion ≠ ACE 1C cargo release**

CPSC says the **1C** message releases cargo, not the 1USG message. A **May Proceed** message can therefore be useful CPSC evidence without proving that CBP has released the package or that the carrier has resumed movement.

If your carrier says the package is still not released after a CPSC message, ask the broker/filer to verify the separate CBP cargo-release state rather than treating the CPSC message as final customs release.

## The CPSC shipment tracker is useful, but it is not the final release system

The [CPSC Import Shipment Tracking Tool](https://www.cpsc.gov/Imports/CPSC-Import-Shipment-Tracking-Tool) can provide CPSC review information when the required entry number, including filer information, is available.

CPSC explicitly warns that statuses in this tool are **not official CPSC or CBP release messages**. Do not treat the tracker as the universal system of record for cargo release.

If you are an ordinary recipient and do not have the necessary entry information, do not post the entry number or filer code publicly to get help. Ask the authenticated carrier, broker, seller/importer, or other responsible entry actor to inspect the official record.

## A formal CPSC detention or formal CBP notice changes the owner

A **CPSC Notice of Sampling and Detention** is a stronger evidence object than an ordinary eFiling request or review message. CPSC says that notice identifies the reason for detention and the CPSC investigator handling the matter.

If you have that formal CPSC notice, use the instructions and contact identified through the current CPSC import process. This page can help you recognize that the case has moved beyond ordinary eFiling/message classification, but it does not choose evidence strategy, response strategy, or a substantive admissibility position for a formal detention.

CPSC and CBP are also separate authorities. CPSC states that separate CPSC and CBP detention notices can coexist, and one agency's release does not necessarily resolve the other agency's separate detention.

If an authenticated **CBP Notice of Detention** or **CBP Notice of Seizure** becomes the controlling object, leave this workflow and use [CBP Detention or Seizure Notice for a Package](/international-shipping/cbp-notice-of-detention-or-seizure/).

If an FDA Notice of FDA Action or independently verified FDA/ITACS state becomes controlling, use [FDA Notice of FDA Action for an Imported Package](/international-shipping/fda-notice-of-fda-action/).

## FedEx, UPS, and DHL use different intake workflows

Carrier pages are useful for understanding what that carrier may ask you to provide. They do not define federal CPSC law.

- **FedEx:** current [FedEx U.S. guidance](https://www.fedex.com/en-us/shipping/international/us-tariffs-impact.html) says required CPSC data still must be provided when FedEx is handling the brokerage workflow, and FedEx does not register products in the CPSC Product Registry for the customer. Missing information can delay the shipment.
- **UPS:** current [UPS U.S. guidance](https://es-us-apps.ups.com/us/en/shipping/international-shipping/tariffs/cpsc) provides UPS-specific submission methods and says a shipment may be delayed when UPS is acting as IOR until the required data are received. Use that only as a UPS workflow statement; current CPSC rules control the federal responsibility analysis.
- **DHL Express:** current [DHL regulatory guidance](https://www.dhl.com/discover/en-hk/logistics-advice/import-export-advice/customs-regulatory-updates) says a U.S.-bound shipment lacking required CPSC information may be delayed while DHL Express tries to contact the receiver or shipper. Use the authenticated DHL request or account channel rather than assuming another carrier's intake method applies.

Do not compare carrier HTS-code counts and treat one carrier's count as the legal universe of CPSC-regulated products. CPSC itself controls federal scope, and product-specific applicability requires current official product guidance.

### Mail is a separate lane

For imported finished products arriving by mail, Part 1110 provides a separate path: the finished-product certifier enters the required certificate data in the CPSC Product Registry before U.S. arrival. Do not copy FedEx, UPS, or DHL ACE/brokerage instructions into a mail shipment as if the lanes were identical.

## What to do next

1. **Preserve the exact wording of the shipment-specific object.** Is it a carrier data request, missing-PGA warning, **Under Review**, **Intensive Exam**, **Intensive Exam with Documents Required**, **Hold Intact**, **Hold Intact with Documents Review**, or a formal notice?
2. **Identify who owns the truthful product and certificate information.** Do not assume the parcel recipient has it or must create it.
3. **Identify the compliance/certifier actor separately from the filer or broker.** A broker can transmit the data without becoming the finished-product certifier.
4. **Use the authenticated request channel.** If the carrier or broker requested information, use its current secure workflow; if the issue is an exact CPSC message, use current CPSC import guidance and the broker/filer's entry record.
5. **Check for a stronger government object.** A formal CPSC detention notice, confirmed CBP hold, CBP detention/seizure notice, or another agency's formal notice changes which process controls.
6. **Verify release separately.** A Product Registry record, eFiling submission, CPSC tracker state, or **May Proceed/1USG** message is not a substitute for the CBP cargo-release state.

If you are unsure whether the product was ever subject to a CPSC certification requirement, stop the shipment-status workflow there and use current CPSC product/compliance resources. Do not create a certificate, choose a laboratory, or invent test information based on a package-tracking article.

## If the real problem is not CPSC eFiling

Use the evidence object that actually controls the next action:

- No verified CPSC object and only a generic customs delay → [Package Stuck in Customs](/package-problems/package-stuck-in-customs/).
- A verified request is really for ID, tax number, invoice, or proof → [Customs or Carrier Asks for ID, Tax Number, Invoice, or Proof](/international-shipping/customs-asks-for-id-tax-number-invoice-or-proof/).
- The actual problem is an HS code, value, description, origin, quantity, or invoice mismatch → [Customs Declaration, HS Code, Value, or Invoice Mismatch](/international-shipping/customs-declaration-hs-code-value-or-invoice-mismatch/).
- The controlling issue is broker, IOR, formal-entry, POA, or representation architecture → [Why Does My Package Need a Customs Broker, Formal Entry, or Power of Attorney?](/international-shipping/customs-broker-formal-entry-power-of-attorney/).
- An authenticated formal CBP detention or seizure notice controls → [CBP Detention or Seizure Notice for a Package](/international-shipping/cbp-notice-of-detention-or-seizure/).
- An FDA Notice of FDA Action or independently verified FDA/ITACS state controls → [FDA Notice of FDA Action for an Imported Package](/international-shipping/fda-notice-of-fda-action/).
- Clearance has already failed and return, storage, or disposal is now the primary package question → [Customs Clearance Failed or Package Became Undeliverable](/package-problems/customs-clearance-failed-return-storage-or-disposal/).
- The carrier explicitly identifies a lithium-battery or dangerous-goods transport restriction → [Package or Return Rejected for a Lithium Battery or Dangerous Goods](/package-problems/lithium-battery-or-dangerous-goods-rejected/).
- The CPSC state is already classified and only the correct support actor remains unclear → [Who Should I Contact About a Package?](/delivery-actions/who-to-contact-about-a-package/).

## Do not change customs or certificate data just to make the package clear

Do not choose a different HTS code, change the product description, invent certificate identifiers, substitute false manufacturer or test information, or otherwise misdeclare the goods to avoid CPSC review.

If a customs field is genuinely wrong, correct it truthfully through the party and official process that owns the record. The [customs mismatch guide](/international-shipping/customs-declaration-hs-code-value-or-invoice-mismatch/) explains how to identify the record and responsible correction route without choosing a false classification.

## Keep entry and compliance records private

Do not post or upload a full entry number, filer code, certificate identifiers, Product Registry credentials, ACE credentials, private test reports, commercial invoices, identity or tax records, carrier account credentials, or private CPSC/CBP notices containing personal or business information.

Use those records only in the authenticated official or carrier/broker workflow that requires them.

11Tracking cannot determine product-specific CPSC legal compliance, create a CPC or GCC, perform laboratory testing, submit PGA data, access ACE or Product Registry accounts, access private carrier brokerage systems, contact CPSC/CBP/a carrier for you, release cargo, remove a hold, defeat a detention, or guarantee clearance.

## Official sources and actions

- [U.S. Consumer Product Safety Commission: CPSC Implements Mandatory eFiling for Certificates of Compliance, Targeting Dangerous Foreign Imports](https://www.cpsc.gov/Newsroom/News-Releases/2026/CPSC-Implements-Mandatory-eFiling-for-Certificates-of-Compliance-Targeting-Dangerous-Foreign-Imports)
- [U.S. Consumer Product Safety Commission: Update: Certificates of Compliance and eFiling](https://www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates)
- [U.S. Consumer Product Safety Commission: eFiling Frequently Asked Questions (FAQ)](https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ)
- [Electronic Code of Federal Regulations / U.S. Consumer Product Safety Commission: 16 CFR Part 1110 — Certificates of Compliance](https://www.ecfr.gov/current/title-16/chapter-II/subchapter-B/part-1110)
- [U.S. Consumer Product Safety Commission: eFiling Resources for Importers](https://www.cpsc.gov/efiling/importers)
- [U.S. Consumer Product Safety Commission: CPSC Product Registry](https://www.cpsc.gov/eFiling-CPSC-Product-Registry)
- [U.S. Consumer Product Safety Commission: Import Resources](https://www.cpsc.gov/Imports)
- [U.S. Consumer Product Safety Commission: CPSC Import Shipment Tracking Tool](https://www.cpsc.gov/Imports/CPSC-Import-Shipment-Tracking-Tool)
- [U.S. Consumer Product Safety Commission: CPSC Use of 1USG Notification Messaging at Import — Updated June 2026](https://www.cpsc.gov/s3fs-public/2WayMessagingforCPSCGuidanceDocumentJune2026FINAL.pdf)
- [FedEx: Navigating U.S. Tariffs and Customs Regulations — FAQs CPSC eFiling for U.S. Imports](https://www.fedex.com/en-us/shipping/international/us-tariffs-impact.html)
- [UPS: New CPSC eFiling Requirements](https://es-us-apps.ups.com/us/en/shipping/international-shipping/tariffs/cpsc)
- [DHL Express: Customs Regulatory Updates — U.S. Consumer Product Safety Commission eFiling Requirement](https://www.dhl.com/discover/en-hk/logistics-advice/import-export-advice/customs-regulatory-updates)

## Related 11Tracking guides

- [International Package Tracking and Carrier Handoffs](https://11tracking.com/international-shipping/) — Browse international tracking help by handoff stage, customs status, and local carrier.
- [Package Stuck in Customs: What the Status Means and Who Must Act](https://11tracking.com/package-problems/package-stuck-in-customs/) — Identify the likely customs dependency and which party may need to act next.
- [CBP Detention or Seizure Notice for a Package: Verify the Notice and Find the Official Route](https://11tracking.com/international-shipping/cbp-notice-of-detention-or-seizure/) — Verify a formal CBP detention or seizure notice and route to the correct official case system.
- [Customs or Carrier Asks for ID, Tax Number, Invoice, or Proof: What to Do Safely](https://11tracking.com/international-shipping/customs-asks-for-id-tax-number-invoice-or-proof/) — Verify who is requesting customs information, why it is needed, who owns it, and how to submit it safely.
- [Why Does My Package Need a Customs Broker, Formal Entry, or Power of Attorney?](https://11tracking.com/international-shipping/customs-broker-formal-entry-power-of-attorney/) — Understand an authenticated customs broker, formal-entry, POA, importer-role, or bond dependency and who may act.
- [Customs Declaration, HS Code, Value, or Invoice Mismatch: Who Can Fix It?](https://11tracking.com/international-shipping/customs-declaration-hs-code-value-or-invoice-mismatch/) — Find which customs field or record conflicts, who owns it, and which actor can correct, amend, or review it.
- [Customs Clearance Failed or Package Became Undeliverable: Return, Storage, or Disposal?](https://11tracking.com/package-problems/customs-clearance-failed-return-storage-or-disposal/) — Classify failed customs clearance by cure, authority, custody, disposition, and actual return movement.

### More related guides

- [FDA Notice of FDA Action for an Imported Package: Detained, Released, or Refused?](https://11tracking.com/international-shipping/fda-notice-of-fda-action/) — Classify a real FDA import notice, deadline, and official next route.
- [Who Should I Contact About a Package?](https://11tracking.com/delivery-actions/who-to-contact-about-a-package/) — Identify whether the seller, shipper, or carrier controls the next package action.
- [Package or Return Rejected for a Lithium Battery or Dangerous Goods: What to Check](https://11tracking.com/package-problems/lithium-battery-or-dangerous-goods-rejected/) — Classify a lithium or dangerous-goods rejection, verify acceptance, and find the safe responsible route.

[Browse all Package Help guides](https://11tracking.com/package-help/)