This guide explains what CPSC eFiling means for your US-bound shipments, how to work out which of your products are affected, and what you need to do before it becomes mandatory.

| 🇺🇸 This guide applies to merchants shipping consumer products into the United States. CPSC eFiling becomes mandatory on 8 July 2026.

*CPSC's flagged HTS list is not exhaustive. CPSC has stated that importers remain responsible for CPSC compliance on any regulated product even if its HTS code doesn't appear on the list. A code being absent from the list means it won't be automatically flagged for eFiling — it does not, on its own, mean the product is exempt from CPSC's underlying certification requirements. When in doubt, check with your Swap Account Manager.

The rest of this guide explains how to work out which row applies to each of your products, and exactly how to complete each step.

From 8 July 2026, consumer products shipped into the US must have their safety compliance data filed electronically with US Customs at the point of import. This is called CPSC eFiling, and it applies to products regulated by the US Consumer Product Safety Commission.

This isn't a new testing or safety requirement. What's changing is that you must now file your compliance data with each shipment, rather than keeping it on file and producing it on request.

CPSC has published a list of approximately 591 HTS codes that are in scope. These codes are heavily weighted towards apparel and textiles (HTS chapters 61, 62, and 65), but they also cover toys, furniture, electronics, and other consumer goods. You should not treat "591" as fixed: CPSC has stated the list is guidance, not a safe harbor — it is not exhaustive, and importers remain responsible for CPSC compliance on any regulated product regardless of whether its HTS code is flagged.

Your products are affected if they fall within a flagged HTS code. This includes most clothing (both adult and children's), sleepwear, accessories, and other textile products.

What differs is the treatment. Depending on the product, you'll either need to register it with CPSC or file a disclaim. The section below explains how to determine which path applies to each product.

Applies to: any product primarily designed or intended for children under 13. Examples include children's clothing, baby apparel, sleepwear, toys, furniture, feeding products, and accessories.

Certificate type: Children's Product Certificate (CPC). This must be based on testing by a CPSC-accredited third-party laboratory.

What you need to do: register the product in the CPSC Product Registry and provide Swap with the three resulting IDs. See the registration process below.

Applies to: products subject to a CPSC mandatory standard that don't qualify for an enforcement discretion exemption. This can include certain adult apparel and textile products, particularly those subject to flammability standards (16 CFR 1610) where the specific fabric type or product construction doesn't qualify for the plain-surface textile exemption.

Certificate type: General Certificate of Conformity (GCC). This can be based on your own reasonable testing programme; a CPSC-accredited third-party lab isn't required.

What you need to do: register the product in the CPSC Product Registry and provide Swap with the three resulting IDs. See the registration process below.

How to tell if your adult products need registration rather than a disclaim: when you enter your products into the CPSC Product Registry, the system flags whether each product requires certification based on its HTS code and product details. If it indicates that certification is required, you must complete registration. Products subject to flammability standards where the enforcement discretion exemption doesn't apply are flagged this way. If you're unsure whether your products qualify for the exemption, consult the CPSC eFiling FAQ or contact CPSC directly at [email protected].

A note on testing exclusions: CPSC's guidance describes a third scenario, separate from full registration and from a disclaim. Where a CPSC rule applies to your product but a specific testing exclusion also applies (for example, the 16 CFR 1610.1(d) fabric exemptions applied to wearing apparel), you may still need to file a certificate — just with a testing exclusion code instead of individual test data — rather than registering with full test data or filing Disclaim B. This is a different outcome from Disclaim B, which applies only where CPSC has determined no certificate is required at all. If a product's status is unclear, check with your Swap Account Manager or CPSC directly rather than defaulting to registration or a disclaim.

Applies to: products that either aren't regulated by CPSC at all, or fall within CPSC's scope but qualify for an enforcement discretion exemption (meaning CPSC doesn't require a certificate). The most common example for Swap merchants is adult wearing apparel that qualifies for the plain-surface textile exemption under 16 CFR 1610.1(d).

What you need to do: populate the correct disclaim code and intended use code, and provide them to Swap. You don't need to interact with the CPSC Product Registry at all. See the disclaim section below.

⚠️ Note: Swap's classification is provided as guidance. You're responsible for verifying the accuracy of HTS codes and CPSC treatment for your products, as the disclaim or certificate filed at entry is a legal attestation under US law.

Go to the CPSC Product Registry and create a Business Account. You'll set up your Certifier ID, a short alphanumeric name for your company (e.g. "ABCCo"). You only need to do this once.

For each product, you'll need:

For children's products (CPC): testing must be performed by a CPSC-accredited third-party laboratory.

For general products (GCC): you may self-certify based on a reasonable testing programme. A third-party lab isn't required but may be used.

If you already hold Children's Product Certificates or General Certificates of Conformity, you already have most of this information.

Enter your product data into the Product Registry. You can do this:

When you save each product, you'll assign a Version ID (e.g. "V1"). This is a version number you control, and you increment it whenever the product's certificate is updated.

Once your data is entered, certify each product in the registry. This is a legal declaration that the information is accurate and complete. Only an account holder with "Certifier" permissions can do this.

After certification, you'll have three identifiers for each product. These are the values Swap needs:

The three values Swap needs per variant are:

How these values reach Swap depends on your integration (API, CSV, or direct metafield entry). They flow through to the commercial invoice automatically once received.

If your product doesn't require CPSC registration, you file a disclaim instead. A disclaim is a formal declaration that the product doesn't require a certificate of compliance. There are two disclaim codes.

When it applies: your product is within CPSC's scope and a CPSC rule, ban, or standard applies to it, but CPSC is exercising enforcement discretion and does not require a certificate. Only certain products meet this. The most common example for Swap merchants is adult wearing apparel for people aged 13 and over that specifically qualifies for the flammability testing exemption under 16 CFR 1610.1(d)(1) or (d)(2) — for instance, a plain-surface fabric at or above the exempt weight, or a garment made entirely from an exempt fiber (acrylic, modacrylic, nylon, olefin, polyester, or wool).

The values Swap needs per variant:

Code 130.006 ("consumer product intended for people aged 13 years or older") is the only intended use code permitted for Disclaim B.

When it applies: either (a) your product isn't regulated by CPSC at all (e.g. it's regulated exclusively by another US agency, or falls entirely outside CPSC's authority) or (b) your product is within CPSC's jurisdiction and HTS scope, but no CPSC rule, ban, or standard actually requires a certificate for it. Common examples of (b) relevant to apparel and accessories brands include hats, scarves, gloves, and adult collectible items.

The values Swap needs per variant:

Again, the above list is not exhaustive. CPSC's guidance also permits 081.XXX (medical device), 090.XXX (military use), 155.XXX (commercial assembly), 940.XXX (compassionate/emergency use), and 970.XXX (export) for Disclaim A in edge cases. See CBP Appendix R (PDF) for the full list of intended use codes.

Consumer-relevant codes are in the 100.XXX and 130.XXX ranges. If you're unsure, 130.000 is the safest general-purpose option.

Yes. Products that require a CPSC certificate are subject to the eFiling requirement regardless of shipment value, including shipments claiming the Section 321 de minimis exemption (currently under $800). Filing a Disclaim Message Set remains optional for all shipments, including de minimis ones, but that option does not waive the underlying certification requirement for products that need one. If a significant share of your US-bound volume ships as de minimis parcels, confirm with your Swap Account Manager how this affects your filing setup.

Swap carries your CPSC data to the carrier on the commercial invoice for shipments made via our integration. Swap doesn't register products or certify compliance on your behalf.

ℹ️ How your data reaches the commercial invoice is evolving. We're actively building automation to reduce manual work. Depending on your integration and timing, your CPSC data may be pulled automatically via API, mapped from a CSV export, or entered directly into Shopify metafields. The data requirements are the same regardless of method. Your Swap Account Manager will confirm the best route for your account during onboarding.

From 8 July 2026:

The practical impact for your customers: orders take longer to arrive, or don't arrive at all.

Completing registration (or confirming disclaim status) as early as possible ensures your data is filed with every shipment automatically, and your entries are processed faster, not slower.

Registration for a large or diverse catalogue takes time, particularly where new testing is needed. If you won't be fully registered by the deadline:

The transition period is a grace window, not a waiver. Enforcement will escalate over time, so treat 8 July as the start of the clock, not a wall you've already missed.

CPSC advises that the registration process can take anywhere from one week to six months, depending on catalogue size. We strongly recommend starting now.

If you have questions about the registration process or need help identifying which of your products are affected, contact your Swap Account Manager or email [email protected] for CPSC-specific guidance.

This guide is provided for informational purposes. As the importer and certifying party, you're responsible for the accuracy of your CPSC registration data and disclaim declarations. Swap Commerce does not register products or certify compliance on your behalf.