By: Brian Walczyk, Compliance Manager, TradeInsights, LCB, CCS

Effective July 8, the Consumer Product Safety Commission (CPSC) will move the eFiling of Certificate data from its Beta phase to “Go-Live”. We have compiled best practice instruction for providing the necessary information to your Broker to meet these requirements.

Purpose: CPSC will aim to use this eFiling data to be more targeted with CPSC Examination – ideally, this should equate to fewer examinations for many importers and perhaps more exams for those importers of what CPSC considers “High Risk” products.

CPSC has required testing and certificates on products they regulate; however, there are two changes of note:

1. The scope of products regulated by the CPSC has increased. If you are unsure if your product is regulated by CPSC, they provide a quick start guide here; or you can consult with the Regulatory Compliance arm of our TradeInsights team.
2. The eFiling of certificate data is changing. Rather than uploading CPSC certs when requested, CPSC now requires a pro-active reporting of Certificate data which will work in conjunction with ACE — allowing regulators to target shipments of interest for further review.

Requirements: There are 7 data points to be declared to CPSC; as always with PGA (Partner Government Agency) reporting, this can be done with either a:

• Reference PGA Message set in which minimal data is cross-referenced with the CPSC Product Registry for additional detail.
  • For Importers who have created records in the CPSC Product Registry below are the 3 datapoints required to report at time of entry (Found in your Product Registry / CPSC account):
  • Certifier ID
  • Product ID
  • Version ID

–Or–

• A Full PGA Message set in which all 7 data points are sent along with the entry. For full PGA Message sets, below are the 7 data points required
  • Product ID
  • Citation Codes
  • Manufacture Date
  • Manufacture Place
  • Product Test Date
  • Testing Laboratory
  • Point of Contact

Execution: The Gold Standard for all matters of Import is to construct your Commercial Invoice in the manner which you require your entry to be filed. This applies to standard CIV data points as well as any other reporting (PGA / License / Permits) you need completed.

We highly recommend Importers register with the CPSC, and create a record for all the SKU you wish to Import in the product registry found here. All Importers who wish to use the “Reference PGA Message Set” must have products registered with the CPSC in this way.

Because this is an item level regulatory requirement, either the reference or the full PGA Message set must be added to your commercial invoice, per line. V. Alexander can maintain product databases for its customers, but CPSC testing is an annual requirement. The implication of course is that at minimum, Version ID’s will be updated once a year – Importers will have to work closely with Suppliers, Testing Facilities, and Brokers to be sure the latest, most accurate information is provided.

Providing Commercial Documents (with CPSC reporting requirements) as early in your shipment process as possible (ISF or booking!) is certainly best practice. Because this is a new, quite large shift in regulation, Importers should expect some delays and work with their Broker’s to eFile about 5 days prior to arrival at Port of Entry.

All Importers should also review at minimum the eFiling QuickStart guide found here.

We will continue to monitor this situation and issue updates as needed. Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.