What Is CPSC eFiling?

CPSC eFiling is the U.S. Consumer Product Safety Commission's electronic filing system that requires importers to submit product safety data to CPSC before consumer goods clear U.S. Customs. It operates through ACE (Automated Commercial Environment) via Partner Government Agency (PGA) message sets.

Since March 2024, CPSC eFiling is mandatory for virtually all imported consumer products — from apparel and electronics to toys and furniture. If you import consumer goods into the United States, you must file or your shipment will be held at the port.

Who Is Affected?

• Importers of Record — any company that brings consumer products into the U.S.
• Customs brokers filing on behalf of importers
• DTC (direct-to-consumer) brands sourcing from overseas factories
• Amazon FBA sellers importing private-label products
• Small businesses — there is no size exemption; even one shipment triggers the requirement

Timeline

• March 2024 — CPSC eFiling became mandatory for all consumer product imports
• 2025 — RAM 2.0 risk scoring went live, increasing automated holds
• 2026 — Enforcement tightening; non-compliant shipments face higher refusal rates

The 7 Mandatory PGA Data Elements

Every CPSC eFiling submission requires these seven data elements, transmitted via PGA message set in ACE:

#	Data Element	Description
1	Product Description	Clear, specific description of the consumer product
2	Product Identifier	Model number, SKU, or unique product code
3	Foreign Manufacturer	Name and address of the overseas manufacturer
4	Testing Lab	CPSC-accepted laboratory that tested the product
5	Test Report Number	The reference number for the lab's test report
6	Applicable Rule/Ban/Standard	The CPSC regulation the product must comply with (e.g., 16 CFR 1610 for flammability)
7	Disclaimer Code	Disclaimer A or Disclaimer B — determines the filing pathway

Disclaimer A vs. Disclaimer B

This is where most importers get confused — and where mistakes cause the most port delays.

Disclaimer A — "Not Subject to a Children's Product Safety Rule"

Use Disclaimer A when your product is a general-use consumer product (not primarily intended for children 12 and under). Examples: adult clothing, kitchenware, general electronics, furniture.

Disclaimer A filings require fewer data elements and generally face lower scrutiny, but you must be correct in your classification. If CPSC determines the product is actually a children's product, you face penalties and seizure.

Disclaimer B — "Subject to a Children's Product Safety Rule"

Use Disclaimer B for any product primarily intended for children 12 years old or younger. This includes toys, children's apparel, nursery furniture, feeding products, and more.

Disclaimer B requires:

• A valid Children's Product Certificate (CPC)
• Testing by a CPSC-accepted third-party lab
• Full test report reference numbers
• Compliance with all applicable children's product safety rules (lead content, phthalates, flammability, small parts, etc.)

RAM 2.0 — Risk Assessment Methodology

RAM 2.0 is CPSC's automated risk-scoring system that evaluates every eFiling submission in real time. It assigns a risk score based on:

• Product category risk — children's products, electronics, and flammable goods score higher
• Country of origin — certain manufacturing regions trigger elevated risk
• Importer history — past violations or holds increase your score
• Data completeness — missing fields or vague descriptions raise flags
• Pattern matching — products similar to recently recalled items score higher

High-risk scores trigger automated holds, meaning your shipment sits at the port until CPSC reviews it — which can take days or weeks. Low-risk scores get expedited clearance.

How ClearPort AI Helps

ClearPort AI automates the hardest parts of CPSC eFiling:

• Disclaimer classification — our AI determines whether your product requires Disclaimer A or B based on product attributes, age grading, and CPSC precedent
• PGA data validation — we check all 7 data elements before you file, catching errors that cause holds
• Risk scoring preview — see your estimated RAM 2.0 risk score before submission so you can fix issues proactively
• Compliance audit — our free audit tool scans your product catalog and identifies which items need eFiling attention
• CPC generation — for children's products, we help generate compliant Children's Product Certificates