Importers' Trade and Product Safety Teams Should Review CPSC eFiling Process as Deadline Nears
As the Consumer Product Safety Commission’s mandatory eFiling deadline nears, importers need to bring their trade and product safety teams together to review the process and gather the necessary certificates, a broker and CPSC officials said during a June 3 webinar.
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Importers should become familiar with the eFiling system while the voluntary stage is still open, they said. The requirement becomes mandatory on July 8. After that date, if importers don't submit eFiling data for a product, it could result in a violation or enforcement action.
“It's never too late to get started early,” said Courtney Peterson of Expeditors, who has participated in the voluntary stage.
Peterson said the voluntary process has been very smooth, but it has required a lot of workshopping and making sure they have all the detailed information and the right people in the room. Putting certificate data into the registry is only the first step of compliance, and it’s also necessary to have the product’s certifier ID, the product ID and the version ID.
“Bringing that to the table, knowing your entries and knowing how to connect them, that's the golden method,” she said.
Peterson said to get started, importers should contact their brokers and labs, and work with product safety teams. She said the most successful thing she’s been doing with her clients is picking a product and following it through the eFiling process, including from both an entry filing and certificate data perspective.
Importers can also do test sets in the product registry, where importers can store the certificate data, said Brian Holsey, CPSC's eFiling development and support team lead. The registry doesn’t support the deletion of product certificates or trade parties, but importers can archive them instead. He advised against entering high volumes of test data into the registry because they will permanently exist on the account.
Holsey said it's likely CPSC is adding trade party management features in the future to help users keep data sets organized. For now, the eFiling certificate registry includes "product collections," which are folders managed by business account administrators to store subsets of data and manage access controls. The collections are intended to be very flexible, so importers should organize them in the way that makes sense for their business and suits their internal access needs.
Peterson said importers can’t just rely on which products are flagged to tell them to eFile, so they need to talk to their product safety teams to see which products have certificates.
Kat Rickerson, an eFiling program specialist in CPSC's Office of Import Surveillance, said if importers don't eFile a product that has a certificate requirement after eFiling becomes mandatory, the likelihood of the shipment being stopped, held or examined goes up, which may result in receiving a CPSC violation.
The same applies if an importer uses a Disclaimer Message Set for a shipment to avoid submitting a certificate. Disclaims should only be submitted if no certificate is required, according to CPSC's guidance. Peterson said disclaims are an “interesting hurdle” as importers cannot save them in the product registry, so importers should work with their brokers.
Peterson said there’s a common misconception that CPSC's regulatory scheme has changed, but certification and import requirements remain the same; the certification and import process just need to be connected.
“Nothing changed on the regulatory side. It's all business as usual. It's purely just digitizing that certificate information at the time of entry,” she said.