The final implementation date for CPSC E-filing for baby carriers and other products is July 8, 2026. This is a US regulation that applies to all imported products that are intended for resale.
Although this article will focus on e-filing for baby carriers and slings, the new regulation applies to ALL consumer products, particularly products subject to any regulatory standard.
This means that if you make any other products in addition to baby carriers, you will need to prepare for the e-filing process for those products as well.
Who needs to participate in e-filing?
- Manufacturers and brands who import products into the US that were made outside the United States
- Retail stores, Amazon importers, or anyone else bringing products into the United States with the intention to resell them
- Companies who sell import white-label products to the US under their own brand name
- US importers of any products subject to CPSC regulations. This includes all children’s products as well as many products intended for adults
Definitions and acronyms to understand when navigating e-filing for baby carriers and other products
| Term | Acronym | Definition |
| Automated Commercial Environment | ACE | CBP-operated Electronic Data Interchange system |
| Customs and Border Patrol | CPB | The US agency tasked with ensuring imported goods meet legal requirements, preventing illegal entries, and facilitating lawful trade. |
| Children’s Product Certificate | CPC | A legal document required for all children’s products sold in the US, which certifies that the product meets the requirements of the CPSA. |
| Consumer Product Safety Act | CPSA | The law that gives the CPSC the authority to enforce regulatory compliance. This law was significantly updated by the Consumer Product Safety Improvement Act (CPSIA) in 2008. |
| Consumer Product Safety Commission | CPSC | The agency tasked with overseeing consumer products sold in the US |
| Electronic Data Interchange | EDI | The electronic exchange of business documents between trading partners |
| Message Sets | – | The information required for a product’s CPC |
| Partner Government Agency | PGA | The agency that partners with CBP to regulate a particular product being imported — in this case, the PGA for consumer products is the CPSC |
What is e-filing?
E-filing is a way for the CPSC to better manage compliance for products imported to the US. It’s an online registry of compliance documents that are connected to your company and shipments that allows Customs and Border Patrol to identify products that may not be compliant.
EFiling requires importers of regulated consumer products to electronically file
(eFile) data elements from a certificate of compliance with the U.S. Customs and Border
Protection (CBP), via a Partner Government Agency (PGA) Message Set/
16 CFR Part 1110 is the rule that governs electronic filing of product certification documents.
Your company will be assigned a score based on your eFiling documents and status that will impact how frequently your imports are flagged for inspection.
Does this impact me if I only import a few items at a time?
Yes. There is no de minimus exemption for e-filing products. Even if you are importing only a few products in a small box via USPS, you must use participate in the efiling for baby carriers, slings, and other children’s products.
In fact, the CPSC commissioner has specifically stated that the agency will be focusing on small shipments as a priority in the upcoming year.
I own an international brand. Can I create an account to complete the eFiling process?
EFiling business accounts must be created by the US importer or their affiliate. Third parties, such as brands located outside the US, cannot create these accounts.
After the importer creates a Business Account, they can invite additional users from trade partner organizations to collaborate, such as brokers, testing laboratories, manufacturers, and other external organizations. Once invited, additional users will gain access to the importer’s Business Account to collaborate and support the product certificate data entry process.
If a manufacturer supports multiple importers with certificate data and the entry process, those businesses can invite the manufacturer to join their collection(s). The trade partner can be assigned one of the following roles: collection administrator, collection editor, or collection viewer. The CPSC’s eFiling Quick Start Guide can offer you a better understanding of the eFiling requirements for importers and the corresponding roles and responsibilities across trade partners.
What if I make a mistake or don’t participate in eFiling?
For now, products will not be denied at the border if eFiling is completed incorrectly or not completed at all. The CPSC intends to start by issuing warnings. However, noncompliance will cause your score to be lower, which may lead to import delays in the future, and over time, the CPSC is likely to begin issuing penalties and/or refusing to admit the product into the United States if eFiling is not completed.
Preparing for eFiling
The most important step you must take to prepare for eFiling is to review your current product compliance documents and process to ensure you are meeting all requirements of the current baby carrier regulations.
If you are a product reseller or a white-label brand, you will need to check with your product manufacturer to collect necessary documents.
- Ensure the product has been tested to the relevant ASTM standard in the last 12 months.
- Review your product registration card to ensure it’s in order. If you use the BCIA + Registria program, ensure the card has the Denver, Colorado address listed and not the McKinney, Texas address.
- Create a spreadsheet of your batch and model numbers.
- Review any additional testing required by the CPSIA, such as testing for pthalates.
- Compile all test reports.
- Review third-party certification documents for your component parts and ensure they are up-to-date.
How do I start?
Each US importing business entity or individual will need to create an account with the registry and upload all relevant documentation before importing their product. Companies can provide third parties access to their account to facilitate the import of information, and may work with their customs broker, the product manufacturer, a service provider, or other entity to complete the efiling process.
The CPSC has provided extensive information and documentation to help companies register with the system and complete the efiling process.
Visit the CPSC’s efiling page to start the process.
The volunteer eFiling program has been opened to all participants. Previously, the number was capped at 2000, but now anyone can register and begin working on getting their products registered. Mistakes made during the voluntary program will not impact your company’s score. We strongly recommend participating in the voluntary program as soon as possible to allow you to be prepared for the full implementation in July.
Can you give me a more detailed overview of the process?
The CPSC has created a “quick-start” guide for those new to eFiling. The following checklists are taken directly from that guide. We recommend reading the guide in full, as it offers a great deal of additional information.
The CPSC guide breaks implementation of the eFiling process into three phases:
Phase 1: Learn, Define, Communicate
Receive eFiling Update Notifications
- Add your business email to CPSC’s mailing list to receive direct notification of the latest eFiling updates
Learn more about the eFiling Program
- Visit the CPSC eFiling webpage at www.cpsc.gov/eFiling
- Review the eFiling Document Library
- Identify products subject to CPSC regulation
- Identify all product certificate data elements for collection
- Watch CPSC Product Registry training modules
- Study the available resources on the webpage to understand the eFiling requirements, processes, and data elements
Inform your Importer Trade Network
- Implement formal email communications, meetings, and calls to spread awareness across all internal and external stakeholder channels to include importer, broker, laboratory, manufacturer, and software developer contacts
- Discuss eFiling requirements and specific roles and responsibilities
- Identify specific points of contact for continued communications
- Establish a schedule of communication on a continual basis
- Work with your software developer to understand Application Programming Interface (API) integration requirements, if applicable
Phase 2: Integration and Development
Develop Business Processes
- Decide whether your business will proceed with Full PGA Message Set, Reference PGA Message Set, or both to complete the ACE transmission process
- Designate Business Account Administrator from importer’s business to create an account in CPSC Product Registry (if choosing to file Reference PGA Message Sets)
- Communicate with CPSC your designated initial Business Account Administrator
- Establish your Business Account in CPSC Product Registry
- Decide whether your business will proceed with manual entry or bulk entry via CSV or API
- Identify software developer trade partner for API integration, if applicable
- Reach out to CPSC to obtain Product Registry access for software developer to begin API integration, if applicable
- Invite users from trade partner organizations to begin collaborating and testing in the Product Registry
Identify Data Collection Requirements
- Understand Product Registry user roles and responsibilities
- Understand specific data elements required from each stakeholder in eFiling process
- Identify data owners and systems that will collect critical data needed for eFiling
- Coordinate with data owners and communicate data requirements and timelines
- Learn Product Registry manual and bulk upload processes
- Ensure comprehensive understanding of Certificate Identifiers for Reference PGA Message Set (Certifier ID, Product ID, Version ID)
Test Product Certificate Data
- Establish connected data flow from the importer to the Product Registry to the broker (Reference
- PGA Message Set) or from importer to broker (Full PGA Message Set) for transmission into ACE with all required data elements
- Develop established IT systems to enable data transfers across the entire eFiling ecosystem
- Enter trade party data into Product Registry to initiate product certificate data entry
- Compile and format certificate data to prepare for entry into Product Registry (Reference PGA Message Set) or into ACE (Full PGA Message Set)
- Begin API testing in Product Registry, if applicable
- Begin manual entry or bulk entry (CSV upload or API) testing, if applicable
Phase 3: Implementation and Improvement
Begin eFiling
- Transition to full implementation of eFiling product certificate data for transmission into ACE
- Collaborate within Product Registry Business Account to enter and certify more product certificates in CPSC Product Registry
- Enter larger volumes of product certificate data as process solidifies
- Complete API integration, if applicable
File PGA Message Set into CBP ACE
- Certify completed Certificates of Compliance in CPSC Product Registry if filing Reference PGA Message Sets to prepare for entry
- Coordinate with broker to communicate Certificate Identifiers for filing Reference PGA Message Set
- Coordinate with broker to communicate all seven data elements of Certificate of Compliance for Full PGA Message Set
- File Message Set into ACE system at time of entry
Start the eFiling process now
We suggest starting with one of these three steps. It’s a lot to figure out, but we’ll do our best to make it easier for you!