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Help Coming on New CPSC eFiling Requirement

Next year, the U.S. Consumer Product Safety Commission (CPSC) is expected to begin requiring importers to file a digital General Certificate of Conformity (GCC) for all clothing storage units. AHFA has slated a members-only webinar at 2 p.m. EST on Wednesday, March 20, to review the CPSC initiative, which calls for the GCC to be sent to U.S. Customs and Border Protection through its Automated Commercial Environment (ACE) interface before goods arrive in the United States. Register for the webinar by clicking HERE.

CPSC included the eFiling requirement in a Supplemental Notice of Proposed Rulemaking issued in December 2023. If adopted by CPSC this year, importers will likely need to begin providing GCC data electronically in a secure CPSC registry sometime in early 2025.

The Consumer Product Safety Act, as amended by the Consumer Product Safety Improvement Act, requires manufacturers, importers and private labelers to certify their products’ compliance with consumer product safety rules by issuing certificates accompanying each product.

The agency began contemplating the need for eFiling around 2012, when the rise of internet selling and direct-to-consumer shipments made CPSC’s interdiction of non-compliant products more challenging. To address those concerns and to enable the agency to use data from the GCC for targeted enforcement of product safety rules at the ports, CPSC proposed implementing eFiling for all regulated, imported products. (GCC’s must be completed for domestically-produced products, but only importers will be required to participate in eFiling.) This proposal was included in a 2013 Notice of Proposed Rulemaking.

However, eFiling was not feasible at that time due to the lack of an information technology infrastructure for CBP to accept such data. Since then, CBP has completed its ACE interface enabling importers or their brokers to submit electronic import data.

In 2016 and 2017, CPSC conducted an alpha pilot involving eight volunteer companies that successfully eFiled a limited set of data for their regulated products. In December 2020, the Commission approved a multi-year plan to implement eFiling, including a beta pilot in the fall of 2023 involving more than 30 companies and 300 Harmonized Tariff Schedule (HTS) codes. This was followed by the Supplemental Notice of Proposed Rulemaking in December 2023 specifically addressing eFiling.

The GCC is a written certification that products comply with applicable product safety standards. For clothing storage units, the GCC must verify compliance with the STURDY Act (16 CFR Part 1261) and compliance with the lead paint limit for general use furniture articles (16 CFR Part 1303).

When related to children’s products, the certificate is called a Children’s Product Certificate (CPC), and compliance with STURDY, the lead paint limit and the lead content limit for children’s products must all be verified by third-party testing.

GCCs and the proposed eFiling system also will be the subject of a session at AHFA’s Regulatory Summit August 7-8 at The Conference Center at Guilford Technical Community College