What Your Customs Broker Will — and Won't — Do for CPSC eFiling

"My broker handles that" may be the most expensive sentence in import compliance. Customs brokers are essential to CPSC eFiling, and most importers will never touch a filing screen themselves. But the rule draws a clear line between transmitting data and owning it, and importers who blur that line tend to discover the difference at the worst possible moment: at the port, after July 8, 2026.

• Classify your goods. Brokers assign Harmonized Tariff Schedule (HTS) codes. That matters here because on January 27, 2026 the Consumer Product Safety Commission (CPSC) circulated a list of roughly 600 HTS codes flagging products likely to require eFiling.
• Transmit the filing. Brokers send the CPSC Partner Government Agency (PGA) Message Set, or the three Product Registry identifiers (Certifier ID, Product ID, Certificate Version ID), to U.S. Customs and Border Protection (CBP) through the Automated Commercial Environment (ACE) as part of the entry.
• File the ISF. The Importer Security Filing for ocean shipments.
• Handle CBP queries. When customs has questions about an entry, the broker manages the back-and-forth. Broker fees are commonly cited at $75 to $200 per entry.

• Arrange or pay for product testing
• Generate test data
• Create your Children's Product Certificate (CPC) or General Certificate of Conformity (GCC)
• Attest that your product complies
• Absorb your liability

These are not gaps in service; they are the legal structure. The seller or importer must commission the testing (a CPSC-accepted third-party lab for children's products), create and maintain the certificate, and deliver the data elements to the broker before arrival. A broker filing does not transfer liability.

The eFiling rule names a role called the finished product certifier. That is the party who owns the certificate data's validity, accuracy, completeness, and availability. Normally, it is the importer. You.

There is one wrinkle. The importer of record (IOR) who files the entry can be the owner, the purchaser, or an authorized customs broker under 19 U.S.C. 1484(a)(2)(B). Where a broker is the IOR, the filing may identify the owner, purchaser, or consignee as the certifier under 16 CFR 1110.11(a)(3). In every configuration, the certifier role lands on the business that stands behind the product, never on the lab and never on the transmission service.

Plain-English version: the broker is the courier of the data. You are its author and its owner.

In Full PGA Message Set mode, the data elements under 16 CFR 1110.11, which brokers operationalize as roughly seven PGA elements:

• Product identification and description sufficient to match the product to its certificate
• Each applicable rule, standard, or ban
• Finished product certifier name and contact details
• Manufacturer name, address, and contact details
• Testing lab name, address, and contact details
• Date and place of manufacture
• Date and place of testing
• Records-custodian contact details
• An attestation of compliance

In Reference Message Set mode, just the three identifiers: Certifier ID, Product ID, and Certificate Version ID. That requires pre-registering your products in the CPSC Product Registry first. The trade-offs between the two modes are in Full vs. Reference Message Set, and the registration walkthrough is at how to register in the CPSC Product Registry.

Keep the underlying records for five years, and agree with your broker on format and lead time so the data is in their hands well before arrival.

"My broker handles compliance." Your broker handles transmission. The certificate data's accuracy stays yours, and after July 8, 2026, entries without eFiled certificate data risk rejection and holds. CPSC civil penalties currently run up to $120,000 per knowing violation and up to $17,150,000 for a related series of violations, and those attach to the certificate obligations, not to the broker.

"My supplier's test report is my certificate." A test report is evidence. The certificate is a separate document carrying the required data elements, and for imports it is issued by the importer. For children's products, the testing behind a CPC must come from a CPSC-accepted third-party lab; for general-use products, a GCC rests on a test of each product or a reasonable testing program. Either way, a factory report sitting in your inbox is an input, not the output.

"The lab certifies my product." Labs test. They do not certify. The CPC is issued by the importer, not by the factory and not by the lab. If your "certificate" is signed by a laboratory or a manufacturer rather than by your own company, look again before July 8.

With the deadline under four weeks away, the fastest orientation is the importer's guide to the July 8 deadline. Amazon sellers should work through the FBA seller's checklist, which also covers the separate Seller Central compliance track.

See which 2026 deadlines hit your products with the free 2026 Compliance Deadline Checker.

Will my customs broker create my CPSC certificate?

No. Brokers transmit certificate data, classify goods, and file entries, but they do not arrange or pay for testing, generate test data, create certificates, or attest to compliance. Creating and maintaining the certificate is the importer's job.

Who is the finished product certifier?

Normally the importer. Where a customs broker is the importer of record, the rule allows the filing to identify the owner, purchaser, or consignee under 16 CFR 1110.11(a)(3). Whoever holds the role owns the validity, accuracy, completeness, and availability of the certificate data.

If my broker files the eFiling data, does that shift liability to the broker?

No. A broker filing does not transfer liability. The finished product certifier, normally the importer, remains responsible for the data, and CPSC civil penalties currently run up to $120,000 per knowing violation and up to $17,150,000 for a related series of violations.

What do I need to send my broker before my shipment arrives?

In Full Message Set mode, all of the certificate data elements under 16 CFR 1110.11, which brokers operationalize as roughly seven PGA elements. In Reference Message Set mode, three identifiers: Certifier ID, Product ID, and Certificate Version ID, generated when you pre-register in the CPSC Product Registry.

Is my supplier's test report the same as a certificate of compliance?

No. A test report is evidence of testing; the certificate is a separate document with required data elements, issued by the importer. For children's products the underlying testing must come from a CPSC-accepted third-party lab, but the report alone is not a CPC or GCC.