Starting from July 8, 2026, the CPSC of the United States will officially implement a new regulation for mandatory electronic declaration of imported consumer goods. This measure completely ends the era of paper-based compliance certificates and sets a new compliance threshold for Chinese enterprises exporting to the United States. For exporters of products such as children's products, toys, and electronic products, it is essential to lay out a compliance system for electronic declaration of the CPSC in advance, as it is a key prerequisite for seizing the market in the United States.
This regulation applies to the vast majority of imported regulated consumer goods to the United States, including electronic products, toys, clothing, and various children's products, and they must submit their compliance proof documents through the electronic system before customs clearance. For exporters of products from foreign free trade zones, the mandatory effective date of this requirement is postponed to January 8, 2027, and this regulation has no minimum value exemption. Digital declaration has become a mandatory threshold for products entering the United States market, and the traditional paper-based compliance certificate (COC) process will be completely replaced.
The core essence of CPSC electronic declaration (eFiling)
The electronic declaration system implemented by the CPSC aims to fully digitize the traditional paper-based compliance certificate (COC) process. It requires relevant responsible parties to submit standardized electronic compliance certificate documents to the CPSC's customs contact system before the goods arrive at the port.
This transformation is not merely a technical upgrade; it is a key measure by the CPSC to enhance the efficiency of regulating a large number of imported goods and strengthen risk screening capabilities. It will also establish a unified, transparent, and efficient channel for cross-border trade compliance data exchange. For Chinese export enterprises deeply rooted in the United States market, adapting to the new digital compliance environment and mastering the standardized electronic declaration operation are the core issues they must confront at present.
Coverage and Responsibility Entities of Electronic Declaration
This mandatory requirement for electronic declaration covers a wide range and has clear responsibility divisions. There are no value exemption clauses. All imported consumer goods subject to the mandatory safety standards of the CPSC must complete electronic declaration.
▶ Responsibility Entities
◆ Importer (FSI): Bears the primary obligation for electronic declaration and is the first responsible party for compliance declaration
◆ Brand Holder (BPO): Bears joint compliance responsibility and needs to cooperate with the importer to complete the declaration process
◆ Foreign Manufacturer (ODM/OEM): Needs to provide complete and accurate technical documents to support the declaration work
▶ Product Scope
◆ Mandatory Certification Categories: Cover over 3,000 products under the 16 CFR 1-1700 series standards, covering electronic products, clothing, daily consumer goods, and other categories
◆ High-risk Priority Categories: Children's products (CPSIA), durable baby products, lead-containing products, etc., are the key categories for CPSC electronic declaration verification
Key Information to be Submitted in Electronic Declaration
During the customs clearance process, enterprises need to submit complete electronic filing information through the designated system of the CPSC, including:
1. Unique identity information of the product (such as model, batch number, etc.).
2. Information of the responsible party for issuing the compliance certificate.
3. List of CPSC safety regulations/standards that the product complies with.
4. Production date and production location of the product.
5. Date and location of the latest compliance testing of the product.
6. Contact information of the custodian of the test report.
7. Other supporting information required by the CPSC.
Compliance Recommendations for Enterprises
1. Promote the digitalization of existing product compliance archives
Digitize and standardize the filing of all compliance archives (test reports, certificates, production records, etc.) for products exported to the United States, ensuring that the data is traceable, accessible, and compatible with the requirements of the electronic declaration system.
2. Complete the transformation of supply chain data interfaces
Connect the data links among manufacturers, importers and brand owners, enabling efficient communication and sharing of product information, inspection information and production information. This avoids delays in declaration due to data disconnection.
3. Conduct pressure tests on the declaration system
Get familiar with the operation procedures of the CPSC electronic declaration system in advance, conduct simulation declarations and pressure tests to identify potential problems in system operation and data submission, and ensure zero errors during the official declaration.
Warm reminder
The compliance supervision in the US market is moving towards a more digital and refined direction. The mandatory electronic declaration by CPSC is just the starting point. ZRLK suggests that relevant enterprises make early preparations and actively adapt to ensure that their products comply with the latest regulations of the US CPSC, avoiding unnecessary trade losses. Our company has a professional technical team and rich product testing experience, and can provide real-time compliance interpretation and professional technical support to help Chinese export enterprises smoothly enter the US market. If you have any needs, please contact us at any time. Our engineers will serve you immediately!
