Is There a De Minimis Exemption for CPSC eFiling? (No — Here's What That Means)
The short answer
No — twice over. The Consumer Product Safety Commission (CPSC) eFiling rule contains no exemption for low-value shipments. And the de minimis program it might have been exempt from — duty-free entry for shipments valued under $800 — was suspended for all countries effective August 29, 2025.
So if you import products covered by a CPSC safety rule, certificate data must be filed electronically at entry starting July 8, 2026, no matter how small the shipment. Here is how both halves of that answer work.
Part 1: The rule never had the exemption
The final rule — "Certificates of Compliance," 90 FR 1800, published January 8, 2025, amending 16 CFR part 1110 — requires importers to file certificate of compliance data electronically with U.S. Customs and Border Protection (CBP) at the time of entry. The filing travels through CBP's Automated Commercial Environment (ACE) using CPSC's Partner Government Agency (PGA) Message Set.
The rule takes effect July 8, 2026 for all covered imports: commodity entries, informal entries, former de minimis parcels, and international mail through a modified mechanism. The only later date is January 8, 2027 for entries from a Foreign Trade Zone (entry type 06). There are no earlier mandatory phases — anything filed before July 8 happens under CPSC's voluntary eFiling stage.
Notice what is missing from that list: any carve-out for low-value parcels. Small parcels were never exempted — and the Type 86 entry process that once handled shipments under $800 no longer exists, which makes the question doubly moot.
Part 2: De minimis itself is gone
Executive Order 14324, signed July 30, 2025, suspended duty-free de minimis treatment for all countries effective August 29, 2025. CBP's implementation was blunt: non-postal shipments of any value must now file an appropriate entry type in ACE, Type 86 entries may no longer be used, and Section 321 manifest release has been eliminated for low-value commercial shipments. Customs brokers report roughly ten times the filing volume since the change.
Postal shipments work differently — the carrier remits the duty. Through February 28, 2026, that ran on per-item bands of $80, $160, or $200; after that date it is ad valorem only.
And the change is set to outlive the executive order. Section 70531(b) of H.R. 1 repeals de minimis under the Tariff Act effective July 1, 2027. Even if the suspension were lifted tomorrow, the program ends permanently for commercial shipments on that date.
Why the two changes stack
Because de minimis is gone, former under-$800 parcels now flow through standard ACE entries. That is exactly where the CPSC message set attaches on July 8, 2026. A parcel that once cleared on a manifest with no formal entry now generates an ACE entry — and if the product inside is covered by a CPSC rule, standard, or ban, that entry must carry certificate data. We walk through the full chain reaction in the compliance cascade for small-parcel sellers.
The three dates that matter
| Date | What happens | Authority |
|---|---|---|
| August 29, 2025 | De minimis duty-free treatment suspended for all countries; non-postal shipments of any value require an appropriate ACE entry | Executive Order 14324 (signed July 30, 2025) |
| July 8, 2026 | CPSC eFiling becomes mandatory for all covered imports, including former de minimis parcels and mail | 90 FR 1800, amending 16 CFR part 1110 |
| July 1, 2027 | De minimis repealed by statute under the Tariff Act — the suspension becomes permanent law | H.R. 1, Section 70531(b) |
One narrower date sits alongside these: January 8, 2027 for Foreign Trade Zone entries (entry type 06), the only category with a later eFiling start.
What small-parcel importers must do now
- Determine coverage. Obligation follows the product, not the shipment value and not the tariff code alone. CPSC circulated a list of roughly 600 Harmonized Tariff Schedule (HTS) codes on January 27, 2026, but the list is indicative. Start with which products require CPSC eFiling.
- Get certificates in order. Children's products — designed or intended primarily for ages 12 and under — need a Children's Product Certificate (CPC) based on testing by a CPSC-accepted third-party lab. General-use products need a General Certificate of Conformity (GCC) backed by a test of each product or a reasonable testing program. Both are issued by you, the importer — not the factory, not the lab.
- Choose a filing mode. You can transmit the full data set at every entry, or pre-register products and send just three identifiers per entry. The CPSC Product Registry is how the second path works.
- Mail importers, note the special path. ACE cannot process mail, so certificate data must be entered into the CPSC Product Registry before the shipment arrives.
What is at stake
After July 8, entries without eFiled certificate data risk rejection and port holds, and non-certified or non-compliant products risk refusal of admission. The certificate obligations behind the filing carry CPSC civil penalties of up to $120,000 per knowing violation and $17,150,000 per related series of violations. The liability sits with the finished product certifier — normally the importer — and a broker filing on your behalf does not transfer it.
Not sure which of these dates applies to your catalog? Run your products through the free 2026 Compliance Deadline Checker to see which deadlines hit your imports.
Frequently asked questions
Does CPSC eFiling have a de minimis exemption for low-value shipments?
No. The eFiling rule contains no exemption for low-value shipments — and the Type 86 process that once handled low-value entries no longer exists. If a CPSC rule applies to your product, certificate data must be eFiled at entry regardless of shipment value.
When did de minimis duty-free treatment end?
Executive Order 14324, signed July 30, 2025, suspended duty-free de minimis treatment for all countries effective August 29, 2025. Separately, Section 70531(b) of H.R. 1 repeals de minimis under the Tariff Act effective July 1, 2027, making the change statutory.
When does CPSC eFiling become mandatory?
July 8, 2026, for all covered imports — commodity entries, informal entries, former de minimis parcels, and international mail through a modified mechanism. The only later date is January 8, 2027, for entries from a Foreign Trade Zone (entry type 06).
How do mail shipments handle eFiling if ACE cannot process mail?
Certificate data for international mail shipments must be entered into the CPSC Product Registry before the shipment arrives. ACE cannot process mail entries, so the Registry is the required path for mail importers.
What happens if I import covered products without eFiled certificate data after July 8, 2026?
Entries without eFiled certificate data risk rejection and port holds, and non-certified or non-compliant products risk refusal of admission. The underlying certificate obligations carry CPSC civil penalties of up to $120,000 per knowing violation and $17,150,000 per related series of violations.
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This page is general information for importers and sellers, not legal advice. Regulations change; confirm requirements against official sources or qualified counsel before acting.