Feldman’s Enforcement-First Message: CPSC Is Not Toying Around with Non-Compliant Products

On Monday, February 16, 2026, U.S. Consumer Product Safety Commission (CPSC) Acting Chairman Peter Feldman addressed attendees of the Toy Safety & Legislative Update Seminar at the Toy Association’s Toy Fair trade show and conference in New York, New York. In his keynote, Chairman Feldman reiterated the themes we wrote about from the agency’s recently adopted Fiscal Year 2026 Operating Plan, including:

• The agency’s continuing prioritization of active enforcement, 
• CPSC’s shift away from “measur[ing] success by the number of regulations” it issues,
• The heavy focus on imported products, especially those from China and direct-to-consumer shipments, and
• Increased use of AI tools in identifying imports for scrutiny.

In particular, Chairman Feldman emphasized the forthcoming effective dates for the agency’s rule requiring the electronic filing of compliance certificates for imported products that are subject to one or more CPSC regulations. As we wrote last year, the e-filing rule takes effect on July 8, 2026, for most imports and on January 8, 2027, for products imported through Foreign Trade Zones (FTZs). In his remarks, Chairman Feldman highlighted the value of e-filing for CPSC’s enforcement efforts, saying the rule will allow the agency to more accurately target potentially non-compliant imports. He posited that this will benefit industry, as well, resulting in fewer disruptions of trade for imports that the agency determines to be lower risk.

Chairman Feldman did not address any of the overarching questions surrounding CPSC, such as the four currently unfilled seats on the Commission, the recent nomination of Karen Diebel Sessions to fill one of those seats, or the potential shift of CPSC’s functions to the U.S. Department of Health and Human Services, a move that would require legislative action.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.