CPSC eFiling Compliance

Starting July 8, 2026, importers shipping consumer products regulated by the U.S. Consumer Product Safety Commission (CPSC) must electronically submit product safety certificate data through ACE (Automated Commercial Environment) at the time of entry. This requirement replaces the previous practice of simply maintaining certificates on file.

This guide explains how to include CPSC eFiling compliance data in your ShipStation API integration.

NOTE:
This guide provides technical information for implementing CPSC eFiling compliance via ShipStation API. This is not legal advice. Consult with legal counsel or customs brokers for compliance guidance specific to your business.

INFO:
Carrier support for CPSC eFiling data varies. Verify with your specific carrier that they support transmitting CPSC compliance data to US Customs.

Requirements

Effective Date

July 8, 2026 - Mandatory electronic filing of product safety certificate data at customs entry.

Who Must Comply

Any international business shipping finished consumer products under CPSC jurisdiction to the United States.

Affected Products

The following product categories commonly require CPSC certification:

Children's products (ages 12 and under): toys, clothing, footwear, furniture, car seats
Mattresses and bedding
Bicycles and helmets
Household goods and appliances
Consumer electronics
Textiles and apparel
Imitation jewelry

No exemptions: This requirement applies to ALL shipments of regulated products, regardless of value. There is no de minimis/Section 321 low-value exemption for CPSC eFiling.

Resources:

CPSC Regulatory Robot - Product classification tool
CPSC HTS Code List (PDF) - Verify coverage by HTS code

Filing Methods

You can comply with CPSC eFiling requirements using two methods:

Method 1: CPSC Product Registry (Recommended for API Integration)

Pre-register your product certificates in the CPSC Product Registry Portal. The system generates two reference identifiers that you'll include in your API requests:

Certifier ID - Identifies your organization
Certificate Version ID - Tracks certificate revisions

Once registered, include these identifiers in your ShipEngine API requests as shown in the API Implementation section below.

Method 2: UPS CPSC Form with Document Upload (UPS Recommended)

UPS provides a dedicated CPSC form that can be submitted electronically alongside your shipment. This method is recommended by UPS for merchants shipping via UPS.

How it works:

Download and complete the UPS CPSC Form (PDF)
Save the completed form as a PDF
Upload it electronically using ShipStation API's Carrier Document Upload feature
Select the "other" document type when uploading

Additional step (optional but recommended): If space permits on the Commercial Invoice (150-character limit), you can also manually add the CPSC identifiers for additional reference, even when using the electronic document upload method.

Benefits of using the UPS form:

Comprehensive CPSC compliance documentation in one standardized format
Covers both products registered and not registered in the CPSC Product Registry
Includes testing citations, exemptions, and manufacturer details
Can serve as a blanket document for multiple entries (valid for one year)
Preferred workflow by UPS for UPS shipments

API Implementation

Including CPSC Data in API Requests

CPSC eFiling data is provided at the product level within the packages[].products[] array using the cpsc_certificates array.

CPSC Certificate Object:

Property	Type	Required?	Description
`certifier_id`	string	required	The Certifier ID from CPSC Product Registry (max 50 characters).
`certificate_version_id`	string	required	The Certificate Version ID from CPSC Product Registry (max 50 characters).

Note: The cpsc_certificates array should contain one certificate object for each product that requires CPSC certification. Products are specified using the products array within each package, not the deprecated customs_items array.

CPSC Disclaimer (Exemption)

Use cpsc_disclaim when a product's HTS code is on the CPSC-flagged list, but the specific product does not require a Certificate of Compliance. This tells ACE/CBP why no certificate is being filed and helps prevent shipment holds.

NOTE:
Filing a Disclaim is not mandatory (including for Section 321 de minimis shipments), but CPSC encourages it as it may improve your risk score. You can use cpsc_disclaim and cpsc_certificates on different products within the same shipment, but not on the same product.

CPSC Disclaim Object:

Property	Type	Required?	Description
`disclaim_code`	enumerated string	required	The disclaimer code indicating why no certificate is required. Valid values: `A` - Product Not Regulated by CPSC: product falls outside CPSC jurisdiction (e.g., regulated by FDA), has no applicable CPSC safety standard, or is a B2B part for further assembly. Examples: adult hats/scarves, collectible adult toys, sports helmets (excluding bicycle helmets). `B` - Enforcement Discretion: product falls under CPSC jurisdiction and a rule technically applies, but CPSC is exercising enforcement discretion and does not require a certificate. Examples: adult wearing apparel with flammability testing exemptions under 16 CFR 1610, household refrigerators with a safety certification mark.
`intended_use_code`	string	required	A code from CBP's Intended Use Code list. Must accompany every Disclaim filing. For Disclaim B, must be `130.006`. Max 16 characters. See Intended Use Codes table below.
`intended_use_description`	string		A plain-language description of the product's intended use. Max 100 characters. Recommended by CPSC when `intended_use_code` is `980.000` (Other Use).

Note: Use either cpsc_certificates or cpsc_disclaim per product - not both. One product can only have one disclaim_code, intended_use_code, and intended_use_description per customs entry line.

Intended Use Codes

For Disclaim B: Must use 130.006 (Consumer product intended for people aged 13 years or older).

For Disclaim A: Choose from the following base codes based on your scenario:

Intended Use Code	Meaning
`081.XXX`	For Human Medical Use as a Medical Device
`090.XXX`	For Military Use as a Non-Food Product
`100.XXX`	For Personal Use as a Non-Food Product
`130.XXX`	For Consumer Use (other than standard adult goods)
`155.XXX`	For Commercial Assembly as a Non-Food Product
`970.XXX`	For Export
`980.000`	Other Use - `intended_use_description` recommended

Example: Creating a Label with CPSC Data

POST /v1/labels

POST /v1/labels HTTP/1.1
Host: api.shipengine.com
API-Key: __YOUR_API_KEY_HERE__
Content-Type: application/json

{
  "shipment": {
    "ship_to": {
      "name": "John Doe",
      "address_line1": "123 Main St",
      "city_locality": "Austin",
      "state_province": "TX",
      "postal_code": "78701",
      "country_code": "US"
    },
    "ship_from": {
      "name": "Acme Corp",
      "address_line1": "456 Factory Rd",
      "city_locality": "London",
      "postal_code": "SW1A 1AA",
      "country_code": "GB"
    },
    "packages": [
      {
        "weight": {
          "value": 2.0,
          "unit": "pound"
        },
        "dimensions": {
          "length": 10.0,
          "width": 8.0,
          "height": 6.0,
          "unit": "inch"
        },
        "products": [
          {
            "description": "Children's toy truck",
            "quantity": 1,
            "value": {
              "amount": 24.99,
              "currency": "USD"
            },
            "harmonized_tariff_code": "950300",
            "country_of_origin": "GB",
            "cpsc_certificates": [
              {
                "certifier_id": "CERT-12345",
                "certificate_version_id": "v1.0"
              }
            ]
          }
        ]
      }
    ],
    "customs": {
      "contents": "merchandise",
      "non_delivery": "return_to_sender"
    }
  },
  "carrier_id": "se-123456",
  "service_code": "usps_priority_mail_international"
}

Example: Creating a Shipment with CPSC Data

POST /v1/shipments

POST /v1/shipments HTTP/1.1
Host: api.shipengine.com
API-Key: __YOUR_API_KEY_HERE__
Content-Type: application/json

{
  "ship_to": {
    "name": "Jane Smith",
    "address_line1": "789 Oak Ave",
    "city_locality": "Miami",
    "state_province": "FL",
    "postal_code": "33101",
    "country_code": "US"
  },
  "ship_from": {
    "name": "Global Goods Ltd",
    "address_line1": "100 Export Blvd",
    "city_locality": "Toronto",
    "state_province": "ON",
    "postal_code": "M5H 2N2",
    "country_code": "CA"
  },
  "packages": [
    {
      "weight": {
        "value": 15.0,
        "unit": "pound"
      },
      "products": [
        {
          "description": "Infant car seat",
          "quantity": 1,
          "value": {
            "amount": 149.99,
            "currency": "USD"
          },
          "harmonized_tariff_code": "940120",
          "country_of_origin": "CA",
          "cpsc_certificates": [
            {
              "certifier_id": "CERT-67890",
              "certificate_version_id": "v2.1"
            }
          ]
        }
      ]
    }
  ],
  "customs": {
    "contents": "merchandise",
    "non_delivery": "return_to_sender"
  }
}

Example: Creating a Label with CPSC Disclaimer

Use cpsc_disclaim when your product is exempt from CPSC certification requirements.