| 🇺🇸 This guide applies to merchants shipping consumer products into the United States. It's the companion checklist to The Swap guide to CPSC eFiling for US imports.
Almost every CPSC delay we see traces back to missing or incomplete product data. Collect the fields below once, per product variant, and you'll be able to answer every CPSC question — which products are flagged, whether they qualify for an exemption, and what to file — without a single follow-up round.
The checklist
1. Identify the product
Field | What to provide |
Unique identifier | SKU, GTIN, UPC, model number or serial number — and say which type it is (CPSC requires the type to be declared) |
Product name | As sold |
Customs description | What it is, what it's made of, who it's for and what it's for*. "Adult fashion necklace, gold-plated brass, for casual wear" — not "necklace". Vague descriptions that don't match the HTS code are one of the most common reasons shipments get flagged. |
⚠️ *What it's for is especially important if the product has a safety or special purpose. E.g. if the product is steel-tip boots, make it clear these are intended as safetywear in warehouses and similar environments.
Important: CPSC treats the same product in multiple colours and sizes as one product, provided the variants share the same materials and were manufactured and tested together. Provide your data per style/fabric combination and list the variant SKUs it covers. A style in a different fabric is a separate line.
2. Classify it — the full 10-digit HTS code
This is the single biggest blocker we see, so it gets its own section below. The short version: a 6-digit HS code is not enough, and padding it with zeros makes it worse.
Field | What to provide |
HTS code | The full 10-digit US HTSUS code per variant |
3. The three fabric facts that decide the outcome
For apparel and textiles, these three fields determine whether a product qualifies for the flammability exemption (and therefore Disclaim B) or needs certification. Weight alone won't settle it — we need all three:
Field | What to provide |
Material composition | Fibre content with percentages (e.g. "95% polyester, 5% elastane") |
Fabric weight | In oz/yd² or gsm, for the base fabric |
Surface type | Plain or raised (raised = brushed, napped, pile, terry, chenille, fleece, sherpa) |
Add to that:
Field | What to provide |
Intended age group | Adults (13+) or children (12 and under) — this is what separates the disclaim path from the certification path |
Button/coin cell battery | Yes or no — battery-containing products have their own CPSC rule (16 CFR part 1263) |
Where to find composition and weight: your supplier or manufacturer, tech packs, or spec sheets. If nobody can confirm them, your testing lab can. Don't guess — the values end up in a legal attestation.
4. Who made it, where, and when
Mandatory contents of any CPSC certificate (16 CFR 1110.11) — and US Customs wants the same details for manufacturer identification (MID), so collecting them once serves both:
Field | What to provide |
Manufacturer name | The actual manufacturing company, not your brand name (unless you manufacture) |
Manufacturer address | Complete, including postal code. PO boxes are not acceptable |
Country of manufacture | Per SKU |
Date of manufacture | To at least month and year |
5. The outcome — what gets filed
Once the fields above are in place, each variant resolves to one of three outcomes (see the main eFiling guide for how to determine which):
Field | What to provide |
Determination | Disclaim A, Disclaim B, or Certificate |
Intended use code | e.g. 130.006 for adult consumer products |
For certified products | Certifier ID, Product ID, Version ID — plus test date and your lab's name and address |
Why 6-digit codes won't work (and what to do about it)
If you currently run your entire catalogue on 6-digit HS codes, then upgrading a whole catalogue to 10 digits may feel like a big ask. But if you want to continue shipping to the US, it is unavoidable work.
Why it's unavoidable: CPSC flags shipments on the full 10-digit US HTSUS line. A 6-digit code literally cannot tell you — or us — whether your product is in scope. Until your data carries real 10-digit codes, shipments could be classified incorrectly causing delays and potentially non-compliant shipments.
🚩 Apparel merchants: US HTS codes split apparel by age: the same garment type has separate lines for women's and girls', men's and boys', and babies'. When you only supply a 6- or 8-digit code, the remaining digits get filled in by automated classification further down the chain — and adult garments can end up on a girls', boys' or babies' line. From that moment, US Customs treats your shipment as containing a children's product and expects a Children's Product Certificate that doesn't exist. Supplying and verifying your own full 10-digit codes — and making sure your customs descriptions say "women's", "men's" or "adult" — is the only reliable way to stop this happening.
What not to do: don't pad a 6- or 8-digit code with zeros to reach ten. Codes like 7117190000 are not valid classifications, and they're one of the most frequent root causes of holds that look like CPSC problems but aren't.
Two routes to real 10-digit codes:
Swap's Compliance Hub can generate 10-digit suggestions from your catalogue and write them back to Shopify. You must review and verify them — the classification on your entries is legally yours.
Manual: look up your 6-digit heading at hts.usitc.gov and read down to the statistical suffix matching the actual goods. Material composition decides the classification, not the product name.
Many brands find that items with similar composition and purpose often fall under the same classification, so the workload may not be as immense as you think.
Sending your data to Swap
Send your completed product data through your Account Manager or [email protected]. Two things to know:
Sending data to Swap prepares future shipments — it doesn't automatically release parcels already held at customs. Data has to be transmitted at entry by the customs filer; our team uses your file to make that happen and will confirm.
Strip any personal contact details (names, phone numbers, emails) out of supplier data before sending files on.
What happens next
We map your catalogue against CPSC's flagged HTS list and tell you which products are in scope
Products with complete fabric facts resolve quickly to Disclaim A, Disclaim B or the certification path
Your values are carried onto your shipment data so they're filed at entry — which is what stops shipments being held in the first place
This guide is provided for informational purposes. As the importer, you're responsible for the accuracy of your classifications, determinations and certificate data. Swap Commerce does not register products or certify compliance on your behalf.