If you import your products into the U.S. market, you must be aware of the impact that the eFiling requirements requested by the U.S. Consumer Product Safety Commission (CPSC) can potentially have on your business.
UL Solutions experts collected customers’ frequently asked questions about eFiling. We are sharing them here to help you navigate the challenges of this important regulatory update.
- How will component testing be factored in with eFiling? Can component testing be linked to final product testing in the product registry?
Component testing will not be required; only finished goods testing will be required. Component testing could be used during final product evaluations if allowed by the customer. However, the official eFile must reflect compliance of final, shelf-ready product.
- Does adult apparel that is exempt need to be eFiled?
If something is exempt, like adult apparel, eFiling or disclaiming is optional. However, to avoid potential delays at ports, eFiling is recommended, even for exempt products.
- If a parent company has several child business entities, does each entity need to register with the CPSC and eFile separately, or can they all eFile under one account?
If child business entities are currently listed or considered the importer of record, then, yes, all entities must file separately.
- Will paper General Conformity Certificate (GCC)/Children’s Product Certificate (CPC) still be required after the July 8, 2026, implementation date?
Yes, paper/hard-copy of the Certificate of Conformance (CoC) will be required. Manufacturers and importers are required to furnish them to distributors and retailers and, upon request, the CPSC. The date that the paper documents will be discontinued has not been announced at this time. UL Solutions will continue to issue GCCs/CPCs upon customer request until otherwise advised by the CPSC.
- Do de minimis importers need to eFile?
Yes, even a shipment under $800 would still meet the requirements to be eFiled.
- Who sets up the product registry account?
Importers of record are required to set up their account in the product registry.
- Who will be the business administrator?
The importers of record will be responsible to be the business administrators unless they nominate or invite a trade partner to do so on their behalf (such as a third-party laboratory or broker).
- Who will be authorized to certify product entries on importers of record’s behalf?
The importer of record needs to either certify themselves or invite a trade partner to certify on their behalf.
- How many product collections will be used?
When setting up a company’s account in the product registry, the importer of record will determine the number of product collections. We recommend having only one product collection as well as only the mandatory information required by the CPSC for each eFile.
- What will be the Product ID, and how will this be added to the registry individually?
Each company will need to determine what they will use as the Product ID in the registry. This can be the style number, Universal Product Code (UPC), stock-keeping unit (SKU), etc. It is typically how they track products within the supply chain.
- Who will manage trade partners? What about adding new trade partners, or will all trade partners be entered as new?
Each time a company wants to add a new trade partner, they will need to invite the partner as a separate request, but once they are added to the company’s account in the registry, it will be there going forward.
- How will version IDs be created and tracked?
UL Solutions will create the versions as we file them, and they will be tracked in our system. We are using Indicative version ID's to provide details about when the versions were created.
- Will brokers have access to the product registry? If not, how will they obtain the Registry ID? How often?
If a company invites brokers as trade partners, they will have access to whatever information the importer of recorded chooses for them to have when the account is set up.
- What services will UL Solutions offer to assist clients in eFiling?
UL Solutions offers eFiling on a customer’s behalf as a trade partner, uploading CoC data, testing products as an accredited third-party laboratory, as well as offer advisory services and testing.
- What other services does UL Solutions offer in relation to this topic?
UL Solutions is registered with the CPSC as an accredited laboratory for the Consumer Product Safety Improvement Act (CPSIA) third-party testing. We can also test products as required by regional or federal requirements. Our global team of professionals also offers documentation review.
