Ready, Set, Upload: Meeting CPSC’s eFiling Deadline Without Losing Your Cool

For those who attended the recent International Consumer Product Health and Safety Organization’s (ICPHSO) 2026 Annual Meeting and Training Symposium, one issue came up again and again: eFiling. As we get deeper into 2026, companies are facing the reality of a July 8 implementation date for the U.S. Consumer Product Safety Commission’s (CPSC or the Commission) eFiling requirement — and there has been no indication that the agency will delay the implementation or enforcement of that requirement. As we described previously, CPSC’s eFiling requirement will require all importers of consumer products that are subject to a mandatory safety standard to electronically file data elements from certificates of compliance (general certificates of compliance or children’s product certificates, as applicable).

While we’ve previously focused on the technical elements of eFiling, today, we want to focus on some of the more practical tips picked up from our time at ICPHSO:

• The work starts now! If it’s not there already, putting eFiling to the top of mind now will bring peace of mind later. Rather than waiting until the July 8 deadline, it behooves companies to begin exploring their certification processes and the eFiling requirements now to identify any gaps to fill or kinks to work out ahead of the effective date.
• eFiling impacts more than just the product safety team. Because eFiling pulls in aspects of trade compliance (for example, by needing to identify a product’s HTS code), development of a company’s eFiling program will require coordinating with internal (and potentially external) teams other than product safety.
• Labs are partners in the eFiling process. It is important to speak with your testing lab partners to understand their processes and recommendations for eFiling. Lab partners can be an integral part of an eFiling program’s development. 
• CPSC is likely to be aggressive in enforcing eFiling. CPSC has made it clear that it intends to prioritize U.S. ports of entry.
  • After a drop in 2023, the number of Import Notices of Violation issued by the CPSC has been on the rise, with over 1,000 more notices issued in 2025 than in 2024. For the past three years, the corrective action specified for the vast majority of these violations has been seizure at the port.¹ 
  • In 2025, CPSC increased the number of inspections at ports by 12% and “deployed advanced analytics and risk-targeting tools . . . to better identify suspect shipments from China, intercept unsafe products earlier, and reduce delays for legitimate trade.” ²
  • Additionally, CPSC’s FY26 Operating Plan states that it intends to “continue expanding its surveillance of unsafe imports, particularly low-value e-commerce shipments . . . and supporting mandatory eFiling to identify high-risk shipments before they reach customers.”³ In particular, CPSC has singled out products imported from China for targeting.⁴

CPSC has indicated that, at least initially, the agency “will not reject [entries flagged for potential certificate issues] based upon electronic certificate data provision processing” and that the importers of such entries “will only receive warnings.” However, CPSC has not made clear how long the agency will take this approach or how the potential issues that generate such warnings will affect the importer’s risk score in CPSC’s targeting system.

Ultimately, it’s important for companies to be flexible and prepared to change strategies as they begin or continue working on their eFiling programs. And, if your company has not yet considered how to approach eFiling, the time to start is now! Arnold & Porter is here to help: If you have any questions about how your company can prepare or any other questions about CPSC’s eFiling requirement, please reach out to the authors or any of their colleagues on Arnold & Porter’s Consumer Product Safety team.

© 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.