The Swap guide to CPSC eFiling for US imports

This guide explains what CPSC eFiling means for your US-bound shipments, how to work out which of your products are affected, and what you need to do before it becomes mandatory.

| 🇺🇸 This guide applies to merchants shipping consumer products into the United States. CPSC eFiling was introduced on 8 July 2026 with additional requirements coming into force in January 2027.

At a glance

*CPSC's flagged HTS list is not exhaustive. CPSC has stated that importers remain responsible for CPSC compliance on any regulated product even if its HTS code doesn't appear on the list. A code being absent from the list means it won't be automatically flagged for eFiling — it does not, on its own, mean the product is exempt from CPSC's underlying certification requirements. When in doubt, check with your Swap Account Manager.

The rest of this guide explains how to work out which row applies to each of your products, and exactly how to complete each step.

What's changing?

From 8 July 2026, consumer products shipped into the US must have their safety compliance data filed electronically with US Customs at the point of import. This is called CPSC eFiling, and it applies to products regulated by the US Consumer Product Safety Commission.

This isn't a new testing or safety requirement. What's changing is that you must now file your compliance data with each shipment, rather than keeping it on file and producing it on request.

Does this affect your products?

CPSC has published a list of approximately 591 HTS codes that are in scope. These codes are heavily weighted towards apparel and textiles (HTS chapters 61, 62, and 65), but they also cover toys, furniture, electronics, and other consumer goods. You should not treat "591" as fixed: CPSC has stated the list is guidance, not a safe harbor — it is not exhaustive, and importers remain responsible for CPSC compliance on any regulated product regardless of whether its HTS code is flagged.

Your products are affected if they fall within a flagged HTS code. This includes most clothing (both adult and children's), sleepwear, accessories, and other textile products.

What differs is the treatment. Depending on the product, you'll either need to register it with CPSC or file a disclaim. The section below explains how to determine which path applies to each product.

The three paths

Path 1: Registration required (children's products)

Applies to: any product primarily designed or intended for children under 13. Examples include children's clothing, baby apparel, sleepwear, toys, furniture, feeding products, and accessories.

Certificate type: Children's Product Certificate (CPC). This must be based on testing by a CPSC-accredited third-party laboratory.

What you need to do: register the product in the CPSC Product Registry and provide Swap with the three resulting IDs. See the registration process below.

Path 2: Registration required (general consumer products)

Applies to: products subject to a CPSC mandatory standard that don't qualify for an enforcement discretion exemption. This can include certain adult apparel and textile products, particularly those subject to flammability standards (16 CFR 1610) where the specific fabric type or product construction doesn't qualify for the plain-surface textile exemption.

Certificate type: General Certificate of Conformity (GCC). This can be based on your own reasonable testing programme; a CPSC-accredited third-party lab isn't required.

What you need to do: register the product in the CPSC Product Registry and provide Swap with the three resulting IDs. See the registration process below.

How to tell if your adult products need registration rather than a disclaim: when you enter your products into the CPSC Product Registry, the system flags whether each product requires certification based on its HTS code and product details. If it indicates that certification is required, you must complete registration. Products subject to flammability standards where the enforcement discretion exemption doesn't apply are flagged this way. If you're unsure whether your products qualify for the exemption, consult the CPSC eFiling FAQ or contact CPSC directly at eFilingSupport@cpsc.gov.

Path 3: No registration needed (disclaim)

Applies to: products that either aren't regulated by CPSC at all, or fall within CPSC's scope but qualify for an enforcement discretion exemption (meaning CPSC doesn't require a certificate). The most common example for Swap merchants is adult wearing apparel that qualifies for the plain-surface textile exemption under 16 CFR 1610.1(d). Qualifying is a fabric test, not an age test: it depends on the composition and weight of the fabric, not on who the garment is intended for. The Disclaim B section below sets out the full criteria.

What you need to do: populate the correct disclaim code and intended use code, and provide them to Swap. You don't need to interact with the CPSC Product Registry at all. See the disclaim section below.

How to determine which path applies

1. Check whether your product's HTS code appears on the CPSC HTS Code List (PDF). If it doesn't, CPSC eFiling flagging typically won't apply to that product — but the list isn't exhaustive, and the underlying certification requirement under CPSIA still applies to any regulated product regardless of whether its HTS code is listed. If you're unsure, don't rely on the list alone.
   
2. If your HTS code is on the list, enter your product into the CPSC Product Registry. The system classifies whether it requires full certification (Paths 1 or 2) or qualifies for a disclaim (Path 3).

⚠️ Note: You're responsible for verifying the accuracy of HTS codes and CPSC treatment for your products, as the disclaim or certificate filed at entry is a legal attestation under US law.

The registration process (Paths 1 and 2)

Step 1: Create your CPSC Business Account

Go to the CPSC Product Registry and create a Business Account. You'll set up your Certifier ID, a short alphanumeric name for your company (e.g. "ABCCo"). You only need to do this once.

Step 2: Gather your certification data

For each product, you'll need:

• The product's SKU, UPC, or GTIN (this becomes your Product ID)
• The CPSC safety rules your product complies with (citation codes, available from your testing lab or CPSC's citation list)
• Your manufacturer's name and address
• The date and location of manufacture
• The date of your most recent compliance test
• Your testing laboratory's name, address, and contact details
• A contact person who maintains the test records

For children's products (CPC): testing must be performed by a CPSC-accredited third-party laboratory.

For general products (GCC): you may self-certify based on a reasonable testing programme. A third-party lab isn't required but may be used.

If you already hold Children's Product Certificates or General Certificates of Conformity, you already have most of this information.

Step 3: Register your products

Enter your product data into the Product Registry. You can do this:

• One at a time through the web portal (suitable for small catalogues)
• In bulk by uploading a CSV file (suitable for larger catalogues; a template is available from CPSC)

When you save each product, you'll assign a Version ID (e.g. "V1"). This is a version number you control, and you increment it whenever the product's certificate is updated.

Step 4: Certify your products

Once your data is entered, certify each product in the registry. This is a legal declaration that the information is accurate and complete. Only an account holder with "Certifier" permissions can do this.

Step 5: Provide your three IDs to Swap

After certification, you'll have three identifiers for each product. These are the values Swap needs:

The three values Swap needs per variant are:

• cpsc_certifier_or_disclaim → your Certifier ID
• cpsc_product_or_use_code → your Product ID
• cpsc_version_or_use_desc → your Version ID

How these values reach Swap depends on your integration (API, CSV, or direct metafield entry). Check with support@swap-commerce.com or your Account Manager if you're not sure.

The disclaim process (Path 3)

If your product doesn't require CPSC registration, you file a disclaim instead. A disclaim is a formal declaration that the product doesn't require a certificate of compliance. There are two disclaim codes.

Disclaim B: "CPSC data not required"

When it applies: your product is within CPSC's scope and a CPSC rule, ban, or standard applies to it, but CPSC is exercising enforcement discretion and does not require a certificate. Only certain products meet this. The most common example for Swap merchants is adult wearing apparel for people aged 13 and over that specifically qualifies for the flammability testing exemption under 16 CFR 1610.1(d)(1) or (d)(2) — for instance, a plain-surface fabric at or above the exempt weight, or a garment made entirely from an exempt fiber (acrylic, modacrylic, nylon, olefin, polyester, or wool).

⚠️ "It's adult clothing" is not, on its own, a valid basis for Disclaim B. For the vast majority of merchants, Disclaim B rests on one specific rule: the flammability standard exemption at 16 CFR 1610.1(d). What qualifies a garment is its fabric composition and weight — not the age of the customer. Check your products against the criteria below before filing.

CPSC's own eFiling guidance names adult wearing apparel claiming exemption under 16 CFR 1610.1(d)(1) or (d)(2) as an example of Disclaim B. The basis is CPSC's Statement of Policy at 81 FR 12587, in which it confirmed it will not enforce certification requirements for adult wearing apparel relying on that testing exemption.

Which fabrics actually qualify

Two categories of fabric are exempt from flammability testing under 16 CFR 1610.1(d). If a garment falls into either one, it qualifies for Disclaim B:

Between them, these two categories cover most standard apparel catalogues.

What the exemption does not automatically cover

• Lightweight plain-surface fabrics under 2.6 oz per square yard, unless made entirely from the listed fibres
• Raised-surface fabrics — brushed, napped, pile, terry, chenille, fleece, sherpa — made from other fibres such as cotton, rayon, or silk

🚩 These are the fabrics that catch merchants out. CPSC's compliance guidance names specific fabric types that have caused real violations, recalls, and civil penalties despite seeming low-risk: sheer rayon and silk items, rayon chenille, reverse fleece or sherpa of cotton or cotton blend, and cotton terry cloth. These fall outside the automatic exemption and need actual testing or a supplier guaranty — not a blanket disclaim.

Products excluded from the flammability standard entirely

These sit outside the flammability standard regardless of what they're made from. The first four are the exclusions listed at 16 CFR 1610.1(c); handkerchiefs are excluded separately, via the definition of wearing apparel at 16 CFR 1610.36(d):

• Hats, unless they cover the neck, face, or shoulders
• Gloves 14 inches or less, not attached to another garment
• Footwear not containing hosiery and not attached to another garment
• Interlining fabrics, when intended or sold for use as a layer between an outer shell and an inner lining
• Handkerchiefs not exceeding 24 inches on any side, or not exceeding 576 square inches in area — unless affixed to or sold as part of a garment as decoration or trim

Because no flammability rule applies to these products at all, they generally belong under Disclaim A rather than Disclaim B — see the Disclaim A section below.

Who is responsible

Disclaim B is entirely a self-declaration. Nobody at CPSC reviews or approves it in advance. You are making a specific factual claim about your product's fabric, and you carry full legal responsibility for its accuracy. If you are unsure, the answer is to check with your compliance team, testing lab, or supplier — not to assume it is fine because the product is adult clothing.

An exemption is about testing burden, not proven safety

Being in an exempt category means CPSC's historical data shows those fabric types reliably pass, so testing is not required to support a guaranty. It does not mean a specific batch has been individually verified. If a product turns out to be genuinely flammable despite sitting in an exempt category, that is still a violation.

The values Swap needs per variant:

• cpsc_certifier_or_disclaim: DISCLAIM B
• cpsc_product_or_use_code: 130.006
• cpsc_version_or_use_desc: leave blank

Code 130.006 ("consumer product intended for people aged 13 years or older") is the only intended use code permitted for Disclaim B.

Disclaim A: "Product not regulated by CPSC"

When it applies: either (a) your product isn't regulated by CPSC at all (e.g. it's regulated exclusively by another US agency, or falls entirely outside CPSC's authority) or (b) your product is within CPSC's jurisdiction and HTS scope, but no CPSC rule, ban, or standard actually requires a certificate for it. Common examples of (b) relevant to apparel and accessories brands include hats, scarves, gloves, and adult collectible items.

The values Swap needs per variant:

• cpsc_certifier_or_disclaim: DISCLAIM A
• cpsc_product_or_use_code: the appropriate intended use code (see table below)
• cpsc_version_or_use_desc: leave blank, unless you use code 980.000, in which case provide a short description of the product's intended use

How to find your intended use code

Again, the above list is not exhaustive. CPSC's guidance also permits 081.XXX (medical device), 090.XXX (military use), 155.XXX (commercial assembly), 940.XXX (compassionate/emergency use), and 970.XXX (export) for Disclaim A in edge cases. See CBP Appendix R (PDF) for the full list of intended use codes.

Consumer-relevant codes are in the 100.XXX and 130.XXX ranges. If you're unsure, 130.000 is the safest general-purpose option.

Important notes on disclaims

• Filing a disclaim is a legal attestation under US law. You're declaring that the product doesn't require CPSC certification. Improper use of a disclaim code may result in enforcement action.
• Disclaims are encouraged but not mandatory. CPSC does not require importers to file a disclaim message for products that don't need a certificate, but filing them improves your entry's risk score with US Customs, meaning faster clearance and fewer inspection holds — this is why Swap asks merchants to provide disclaim data as standard practice.
• If you sell a mix of products, multiple paths may apply. For example, children's clothing requires registration, while adult clothing from the same brand can use the disclaim route.

How this works with Swap

Swap carries your CPSC data to the carrier on the commercial invoice for shipments made via our integration. Swap doesn't register products or certify compliance on your behalf.

ℹ️ How your data reaches the commercial invoice is evolving. We're actively building automation to reduce manual work. Depending on your integration and timing, your CPSC data may be pulled automatically via API, mapped from a CSV export, or entered directly into Shopify metafields. The data requirements are the same regardless of method. Your Swap Account Manager will confirm the best route for your account during onboarding.

Your role

• Determine which of your products require registration and which qualify for a disclaim
• Register regulated products in the CPSC Product Registry
• Provide Swap with your registration data via one of the following (your Account Manager will confirm the best route):
  • Automatic API pull from your CPSC Product Collection (Swap is building this)
  • CSV export from the CPSC Product Registry, uploaded to Swap
  • Direct entry into the Shopify variant metafields listed above
• For disclaimed products, provide the disclaim code and intended use code to Swap via the same route

Swap's role

• Provide guidance on how your CPSC data will be ingested during onboarding
• Map your metafield values onto the commercial invoice at line level
• Transmit the commercial invoice to the carrier, who files the data with US Customs at entry
• Assist with HTS classification through our compliance hub (Swap's classification is guidance; you're responsible for verifying accuracy)

What Swap is working on

• A CSV upload tool that takes your Product Registry export and maps it into Shopify metafields automatically, removing the need for manual data entry
• Automating the cross-reference between HTS codes and CPSC's affected code list, so you can see at a glance which of your products are in scope
• API integration with the CPSC Product Registry for merchants who want Swap to pull data directly (future)
• Building defaulting logic so merchants with entirely non-regulated adult catalogues can have disclaim values pre-populated

Frequently asked questions

Can Swap complete our CPSC filing for us?

Swap can do much of the work, but not the determination and not the certification. We can map your catalogue against CPSC's flag list, suggest 10-digit HTS codes, carry your values onto shipment data, and work with the carrier on held parcels. We cannot decide whether a product needs a certificate or a disclaim, and we cannot act as the certifier.

This isn't a policy choice on our side. Under 16 CFR 1110.7(a) the importer is the certifying party. 16 CFR 1110.15 allows you to delegate the filing work to a third party, but not the legal responsibility — the attestation is yours, and knowingly making a false statement on it is a federal offence.

In practice: you make the determination and give us the values, and we handle the mechanics.

Does this apply to low-value (Section 321/de minimis) shipments?

Yes. Products that require a CPSC certificate are subject to the eFiling requirement regardless of shipment value, including shipments claiming the Section 321 de minimis exemption (currently under $800). Filing a Disclaim Message Set remains optional for all shipments, including de minimis ones, but that option does not waive the underlying certification requirement for products that need one. If a significant share of your US-bound volume ships as de minimis parcels, confirm with your Swap Account Manager how this affects your filing setup.

Is "it's adult clothing" enough to justify Disclaim B?

No. For apparel, Disclaim B rests on the flammability exemption at 16 CFR 1610.1(d), which is a test of fabric composition and weight — not of who wears the garment. A cotton terry robe and a sheer rayon slip dress are both adult clothing, and neither qualifies automatically. Check the fabric before you file.

How do I check whether a product's fabric qualifies?

For each product, you need two pieces of information: the surface type (plain or raised) and the fibre content and weight. Then apply the two exemption tests:

• Plain surface and 2.6 oz per square yard or more → qualifies, whatever the fibre content
• Made entirely from acrylic, modacrylic, nylon, olefin, polyester, or wool (or a combination) → qualifies, plain or raised surface, at any weight

If a product meets neither test, it needs proper certification rather than a disclaim.

I don't know my fabric weights or compositions. Where do I get them?

Your supplier or manufacturer is usually the fastest route to confirming composition and weight, and the information is often already on your tech packs or spec sheets. If your supplier can't confirm it, your compliance team or testing lab can. Don't file a disclaim on an assumption.

Which fabrics most often catch merchants out?

Sheer rayon and silk items, rayon chenille, brushed cotton fleece and sherpa, and cotton terry cloth. CPSC's own compliance guidance names these because they have caused real violations, recalls, and civil penalties. As a rule of thumb, anything brushed, napped, pile, terry, chenille, fleece, or sherpa in a non-exempt fibre should be treated as needing certification or a supplier guaranty until you've confirmed otherwise.

Does anyone at CPSC check my Disclaim B before I file it?

No. Disclaim B is a self-declaration with no advance review or approval. The declaration is a legal attestation under US law, and responsibility for its accuracy sits entirely with you as the importer.

My product is in an exempt category. Does that mean it's confirmed safe?

No. The exemption reflects CPSC's historical data showing those fabric types reliably pass testing, which is why testing isn't required to support a guaranty. It isn't confirmation that your specific batch has been verified. A genuinely flammable product is still a violation even if its fabric type sits in an exempt category.

We only have 6-digit HS codes. Is that enough?

No. CPSC flags at the 10-digit HTSUS line, so a 6-digit HS code can't tell you whether a product is in scope. Do not pad a 6 or 8 digit code with zeros to reach ten. That isn't a valid classification, and the shipment will keep flagging.

To find the full code, look your 6-digit code up at hts.usitc.gov and work down to the correct sub-category. Swap's Compliance Hub can also generate 10-digit suggestions and write them back to Shopify, but you'll need to verify them — we can't take responsibility for the classification underpinning your CPSC filing.

Do footwear and bags qualify for Disclaim B?

No — both take Disclaim A instead. Disclaim B rests on the clothing flammability standard, and footwear is excluded from that standard entirely under 16 CFR 1610.1(c)(3). Bags were never wearing apparel, so no flammability rule applies to them either.

The distinction matters. Filing Disclaim B declares that a rule applies to your product and CPSC is choosing not to enforce it — which isn't true of a handbag. Use Disclaim A, and note that 130.006 remains a valid intended use code with A.

Do we need a separate Product Registry record for every colour and size?

No. CPSC treats apparel of the same material in multiple styles, sizes and colours as a single product, provided the items were manufactured and tested together. You register the product family rather than the variant.

The condition matters more than the conclusion: if a style is made from a different fabric, or produced and tested in a separate run, it's a separate product and needs its own record.

What happens if I ship without complying?

From 8 July 2026:

• US Customs will flag shipments that arrive without the required CPSC data
• CPSC will adjust the risk score for your entries, meaning more frequent inspections and holds
• Shipments may be examined, detained, or refused entry
• At launch, CPSC has indicated it will issue warnings rather than outright refusals, but enforcement will escalate over time
• Repeated non-compliance could result in formal enforcement action

The practical impact for your customers: orders take longer to arrive, or don't arrive at all. Completing registration (or confirming disclaim status) as early as possible ensures your data is filed with every shipment automatically, and your entries are processed faster, not slower.

What if I can't complete registration by 8 July?

Registration for a large or diverse catalogue takes time, particularly where new testing is needed. If you won't be fully registered by the deadline:

• Start now and prioritise your US best-sellers. Certified products can ship compliantly as soon as their individual registration completes. You don't need the whole catalogue done to begin.
• Expect warnings, not blockages, at first. CPSC has indicated that at launch, entries missing eFiled data will receive warning messages rather than being refused. However, your risk score will suffer in the meantime, meaning more inspections and slower clearance until your data is complete.
• Speak to your Swap Account Manager. We can help you sequence the work and advise on interim options while your registration completes.

The transition period is a grace window, not a waiver. Enforcement will escalate over time, so treat 8 July as the start of the clock, not a wall you've already missed.

Timeline

CPSC advises that the registration process can take anywhere from one week to six months, depending on catalogue size. We strongly recommend starting now.

Helpful links

• CPSC Product Registry (create your account and register products)
• CPSC eFiling Overview
• CPSC HTS Code List (PDF) (check if your HTS codes are affected)
• Product Registry Training Videos
• CPSC Quick Start Guide (PDF)
• CBP Appendix R: Intended Use Codes (PDF)
• eFiling FAQ
• CPSC-accredited laboratory search (for children's product testing)

Questions?

If you have questions about the registration process or need help identifying which of your products are affected, contact your Swap Account Manager or email eFilingSupport@cpsc.gov for CPSC-specific guidance.

This guide is provided for informational purposes. As the importer and certifying party, you're responsible for the accuracy of your CPSC registration data and disclaim declarations. Swap Commerce does not register products or certify compliance on your behalf.