U.S. CPSC eFILING SYSTEM UPDATE
The U.S. Consumer Product Safety Commission’s eFiling system is still in beta testing, but expected to launch in 2025. Integration with LINK Services will be completed by July 1, 2024, although CPSC expects changes will be necessary based on input from beta testing partners. Contact us if you would like more information about participating as a LINK/eFiling beta site. You do not need to be an existing LINK subscriber to participate.
The CPSC eFiling system provides an API for manufacturers, importers and private labelers of regulated consumer products to register various elements of a product certificate of compliance or declaration with U.S. Customs and Border Protection (CBP), and obtain a unique product ID attesting to that registration. The CPSC and CBP expect organizations will "see reductions in risk scores over time based on the amount of data provided, which may result in reduced hold times, fewer exams and reduced costs to the importer." LINK will continue to serve as the public portal for consumers and other third parties to access your certificates and declarations, and as the private portal for brands, retailers, and supply chain partners to manage product, testing and certification details, including the CPSC-registered product ID.
Note that an optional data element for registration with CPSC is a link (URL) to the lab test report supporting the product safety testing methods and results. If your lab reports have been uploaded into Test Requests and/or Compliance Records in LINK, these can be made accessible to the public in the same manner as product certificates. An optional configuration setting available with the LINK/eFiling integration will automate the approval and publishing tasks, allowing trusted suppliers to self-publish certificates and lab reports.
IMPACT ON BRANDS, MANUFACTURERS AND LABS
The eFiling system is a product registry that contains a set of mandatory (M), conditional (C) and optional (O) data elements:
- • Global Location Number (GLN) or a custom Alternate ID are required when providing a new manufacturer or identifying an existing one (M)
- • Product type identifier, which must be one of the following: GTIN, UPC, SKU, Model #, Serial #, Registered #, Alternate ID (M)
- • Full address of the manufacturer if it is being added to the Business Account for the first time (C)
- • Full address of the laboratory if it is being added to the Business Account for the first time (C)
- • Type of lab ("ITL" or "LAB") is required (M)
- • Full name, address and phone number of the point of contact (POC) if it is being added to the Business Account for the first time (C)
- • Most recent date of testing for the product (M)
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Note: Products that require no testing should not be uploaded to the Product Registry and should instead be filed using a Disclaim message set. This suggests that you, as a brand/retailer or manufacturer, may consider generating a record of disclaimer (in lieu of a certificate) for products exempt from CPSIA (or other regulatory) safety testing to document your assessment of exemption.