March 30th, 2016 the Consumer Product Safety Commission (CPSC) released Version 3.2 of its eFiling Alpha Pilot Implementation Guide. The guide provides updates to required data elements for electronic filing of CPSC date on regulated commodities. Currently the Pilot program is limited to eight approved importers and their Customs Brokers who are filing entries on their behalf. There is no published date for electronic file of CPSC to be mandatory at this time.
What commodities will require electronic filing?
CPSC regulated finished products and the following products included on the Substantial Product Hazard List issued under the Consumer Product Safety Act: hand-supported hair dryers, extension cords, and seasonal and decorative lighting products. Links are provided below for the list of US tariff codes that CPSC is seeking electronic filing of data for, the regulated on Certificates of Compliance and the Substantial Product Hazard regulations.
A regulated consumer product is a finished product that is subject to a consumer product safety rule under the CPSA or similar rule, ban, standard, or regulation under any other law enforced by the Commission that is imported for consumption or warehousing, or distributed in commerce. Regulated products require a certificate of compliance, unless a statutory or regulatory exemption applies.
What information will be required?
At a minimum, Pilot participants will file the five targeting/enforcement data elements listed below:
1. Identification of the finished product – additional information below
2. Each consumer product safety rule to which the finished product has been certified under 16 C.F.R. part 1110;
3. Place where the finished product was manufactured, produced, or assembled, including the identity and address of the manufacturing party;
4. Parties on whose testing a certificate under 16 C.F.R. part 1110 depends (name and contact information of the testing entity); and
5. A check box indicating that a required certificate currently exists for the finished product, as required by Sections 14 and 17 of the CPSA.
Identification of the finished product will include the Product Name (Model) and at a minimum of one of the following five data elements though multiples will be allowed
- GS1 Global Trade Item Number
- Universal Product Code (UPC)
- Stock Keeping Unit (SKU)
- Model Number
- Serial Number
Additional information will be provided as it becomes available.
Additional Resources
CPSC eFiling Alpha Pilot Implementation Guide – Version 3.2
HTSUS Codes that Include Consumer Products for which Electronic Filing is Sought in eFiling Alpha Pilot
16 CFR 1110 – Certificates of Compliance
16 CFR 1120 – Substantial Product Hazard List
