CPSC eFiling for Amazon FBA Sellers: The 2026 Compliance Checklist

The Consumer Product Safety Commission's mandatory eFiling requirement for imported consumer products regulated under a Children's Product Certificate or a General Certificate of Conformity took effect for all covered importers on July 8, 2026, and Amazon FBA sellers whose supplier chain still assumes the old paper-CPC workflow are the ones seeing FBA shipments held at the port with no clear path to release. This is a checklist for the specific Amazon FBA seller case, distinct from the larger-importer case, because the compliance surface for a small third-party seller importing into a Fulfillment by Amazon warehouse network involves both CPSC's requirements and Amazon's own overlay of compliance documentation that Amazon requires before a shipment is accepted at an FBA receiving center.

This article summarizes public CPSC and CBP guidance as it stood at publication and provides a checklist for planning purposes. It is not legal advice. FBA sellers with genuine classification uncertainty, or whose products fall into borderline categories (any product intended for children under 12, plus categories subject to specific standards such as ASTM F963 for toys or 16 CFR 1303 for lead in surface coatings), should confirm classification against a customs broker or product safety attorney before making filing decisions, and should verify current CPSC and CBP requirements against the CPSC's official eFiling program page and CBP's ACE portal documentation directly.

The scope question comes first: is your product actually covered?

The most common (and most expensive) failure mode we see is an FBA seller assuming their product needs eFiling when it does not, or assuming it does not when it does. CPSC's eFiling requirement applies specifically to imported consumer products that require a Children's Product Certificate (CPC) or a General Certificate of Conformity (GCC) under existing CPSC statutes, not to every consumer product broadly. The CPSC's regulated products list enumerates which categories require what type of certificate, and the categorization is driven by whether the product is designed or intended primarily for children 12 years of age or younger (CPC required) or by whether the product falls under a specific consumer product safety rule regardless of age (GCC required).

Sellers importing categories that fall clearly outside CPSC's jurisdiction (adult-only apparel without drawstrings or fasteners at issue, most consumer electronics not covered by a specific rule, and pure decor items without regulated coatings, magnets, or batteries) do not need to eFile at all. Sellers importing anything intended for children, anything with lead-paint surface coating exposure, anything with lithium-ion batteries above certain thresholds, or anything that Amazon separately lists as a Restricted Product needs both the correct CPSC certificate and the accompanying eFiling record. Getting the scope question wrong in either direction (over-filing or under-filing) both create problems: over-filing wastes broker time and creates a compliance record that must be defended if audited; under-filing gets shipments detained at the port with no easy recovery path.

Who actually files: broker vs. seller vs. Amazon

CPSC's eFiling framework accepts three types of filers per shipment: the importer of record (typically the FBA seller or their US-registered entity), a licensed customs broker acting on behalf of the importer, or a designated CPSC filer credential holder. Amazon itself is not the filer for FBA shipments. This is the point that catches the largest number of first-time FBA sellers: the fact that goods are destined for an FBA warehouse does not shift filing obligation to Amazon. The importer of record on the entry documentation remains the responsible party, and that is nearly always the FBA seller (or the seller's Delaware LLC set up specifically to hold the seller of record function) rather than Amazon.

Most FBA sellers filing at any meaningful volume delegate the actual eFiling to their licensed customs broker, since the broker already has ACE portal credentials, CPSC filer registration through the broker's professional standing, and the workflow tooling that eFiling requires. Sellers doing occasional low-volume imports can self-register with CPSC's eFiling portal, but the practical learning curve, plus the cost of getting a single filing wrong (a detained shipment that has to be re-worked at the port), usually makes broker delegation cheaper than self-filing below roughly 20 shipments per year.

The specific documentation your supplier needs to provide

Every eFiling record requires source documentation that ties back to a specific third-party laboratory test of the specific product being imported, not a similar product, not a prior batch of the same product with a materially different bill of materials, and not a manufacturer-supplied assurance that testing was done without a corresponding lab report. For a CPC, this means the CPSIA-required third-party laboratory test performed by a CPSC-accepted laboratory, with a report identifying the specific product model, manufacturer, and manufacturing date range the test applies to. For a GCC, this means test data supporting the specific consumer product safety rule the certificate attests compliance to.

The supplier-side ask that FBA sellers should make before placing any purchase order for a product that will require eFiling is a copy of the current third-party test report, the accepting lab's identity and CPSC acceptance status (verifiable against CPSC's published list of accepted laboratories), and the specific product model or SKU the test covers. A supplier that cannot produce this, or that responds with a general "we test our products" without a specific report, is a supplier that will fail the eFiling requirement when the shipment reaches the port. Getting this documentation before the PO is placed is substantially cheaper than getting it after the container has already left the origin port.

The Amazon overlay on top of CPSC

Amazon's seller compliance policies require documentation for certain regulated categories that overlaps with (but is not identical to) what CPSC requires for eFiling. Amazon separately maintains category-level compliance requirements that can require test reports, certificates, or manufacturer authorization letters as a precondition of listing a product in that category on the marketplace. A shipment that clears customs successfully with valid eFiling can still be blocked at the FBA receiving center, or removed from the Amazon listing, if the Amazon-side compliance documentation is incomplete. The Federal Trade Commission's marketplace liability guidance confirms that marketplace-facilitator obligations and seller-side compliance run in parallel, not as substitutes.

The two systems do not talk to each other. An FBA seller who satisfies CPSC's eFiling requirement has not automatically satisfied Amazon's category compliance requirement, and vice versa. The practical routine is to build documentation once, from the same underlying third-party test report, and then submit the appropriate subset to CPSC through eFiling and to Amazon through the seller central compliance portal. Building it once means the same test report file, the same manufacturer statement, and the same certificate live in one seller-controlled document repository from which both filings pull, rather than being reconstructed separately for each channel.

The 90-day pre-import checklist

Ninety days before a shipment is expected to arrive at a US port is the point at which the compliance workstream should already be in motion. The specific steps, in order:

Confirm the product's CPSC classification: does it require a CPC (children's product), a GCC (specific rule coverage), or no CPSC certificate at all. Document the classification decision with a written note explaining why.

Request the current third-party test report from the supplier, verify the accepting laboratory against CPSC's published list of accepted labs, and confirm the report covers the specific SKU being imported.

If the report is more than 12 months old, or the product's bill of materials has changed since the test, request re-testing before the PO ships. Retroactive re-testing after a customs hold is possible but slow.

Draft the certificate itself (CPC or GCC), referencing the test report by lab, report number, and issue date, listing the specific consumer product safety rules being attested to.

Coordinate with your customs broker on the eFiling submission: confirm the broker has the necessary CPSC filer credentials, provide the certificate and test report, and confirm the ACE entry filing will include the eFiling data element.

Cross-check Amazon's category compliance requirements for the target product category and confirm any additional Amazon-required documentation (safety data sheets, manufacturer authorization letters, category-specific certificates) is in hand before the FBA shipment plan is confirmed.

What happens when a shipment is held

CBP's ACE portal will surface a hold reason code for any shipment detained on a CPSC-related basis, and the hold usually resolves through either the correct filing being submitted (if the original was omitted or incomplete) or CBP releasing the goods to CPSC for further examination. Neither path is fast. A typical CPSC-related hold on a first-time FBA shipment resolves in 5-15 business days if documentation is available and complete, longer if the supplier needs to be contacted to produce missing test reports. During the hold period the shipment sits in bonded warehouse storage at the seller's expense, and any FBA arrival deadline for a launch, restock, or Prime Day inventory commitment is at risk. CBP's Trade Facilitation and Trade Enforcement Act enforcement guidance documents the general enforcement posture that governs how a CPSC-related hold is processed.

The recovery motion, if a hold has already happened, is: contact your customs broker immediately (they see the ACE portal hold code first); identify the specific CPSC-related deficiency the hold cites; produce the missing documentation (test report, certificate, filer credentials) as quickly as the supplier can provide it; resubmit through the broker; and simultaneously communicate with the FBA receiving center on the delayed arrival window so the shipment is not further delayed by a scheduling conflict on the FBA side.

Section 15b reporting: the compliance obligation that continues after eFiling

CPSC eFiling covers the pre-entry compliance certification. It does not extinguish the ongoing Section 15(b) reporting obligation that applies once products are in commerce. Under 15 U.S.C. section 2064(b), a distributor, manufacturer, or retailer (including an FBA seller acting as importer of record) that obtains information reasonably supporting the conclusion that a product it distributes contains a defect that could create a substantial product hazard is required to report that information to CPSC, typically within 24 hours. This applies to every FBA seller, not just to larger importers, and it applies regardless of whether the product was eFiled correctly at import.

A seller that receives an unusual pattern of customer complaints about a specific product (burn injuries, choking incidents, unexpected failures) has a legal reporting obligation independent of Amazon's own product safety operations. Amazon has separate reporting arrangements with CPSC as a marketplace operator, but Amazon reporting does not substitute for the seller's own Section 15(b) obligation. Sellers with any meaningful sales volume should treat their customer complaint stream as a compliance monitoring signal, not just a customer service ticket queue.

FAQ

Do I need CPSC eFiling for products shipped Fulfillment by Merchant (FBM) instead of FBA? Yes. The eFiling requirement is triggered by the import event and the CPSC-regulated status of the product, not by the fulfillment channel. FBM shipments imported into the US under a Children's Product Certificate or General Certificate of Conformity requirement need eFiling in the same way FBA shipments do.

My supplier says they will provide the CPC. Is that enough? No. A supplier-provided CPC does not itself satisfy the eFiling requirement unless the certificate is backed by a specific third-party laboratory test report from a CPSC-accepted lab, tied to the specific SKU being imported. You should ask for the underlying test report, not just the certificate, and verify the accepting laboratory on CPSC's published accepted-lab list.

Can Amazon file on my behalf? No. Amazon is not the importer of record on FBA shipments. The seller (or the seller's US-registered entity) is the importer of record, and the filing obligation flows to whoever is on the entry paperwork as importer of record. Amazon provides the destination FBA address but does not assume the importer role.

What if my product falls into a category where I am unsure whether a CPC or GCC is required? Consult a customs broker or product safety attorney before shipping. The cost of an hour of professional advice is dramatically lower than the cost of a detained container plus per-diem storage fees plus a missed FBA arrival window. CPSC's own Small Business Ombudsman program also provides free classification guidance for small importers.

Does the eFiling data have to be submitted before the shipment sails, or before it arrives? eFiling data is submitted alongside the ACE entry filing at the time of import entry, which is at or shortly before the shipment's arrival at a US port. It does not need to happen before the shipment departs the origin port, but the supporting documentation (test report, certificate) needs to be in your possession before you can file, which is why the 90-day pre-import checklist starts before the goods ship.

Are there penalties for filing incorrectly versus not filing at all? Both create problems. Failure to file for a covered product typically results in the shipment being detained. Filing with false or unsupported information can create additional CPSC enforcement exposure separate from the customs hold, including civil penalties. When in doubt, the answer is to slow down and get the classification right before submitting, not to submit something and hope it clears.

Related reading: our complete CPSC eFiling rule guide walks through the July 8 mandate itself in more detail, and the Section 15(b) reporting guide covers the post-market reporting obligation this checklist references. Run a free scope check on your specific SKU at EntryProof or draft a CPC or GCC from a supplier test report at /cpsc-efile/tool/cpc-generator.

FAQ

Do I need CPSC eFiling for products shipped Fulfillment by Merchant (FBM) instead of FBA?

Yes. The eFiling requirement is triggered by the import event and the CPSC-regulated status of the product, not by the fulfillment channel. FBM shipments imported into the US under a Children's Product Certificate or General Certificate of Conformity requirement need eFiling in the same way FBA shipments do.

My supplier says they will provide the CPC. Is that enough?

No. A supplier-provided CPC does not itself satisfy the eFiling requirement unless the certificate is backed by a specific third-party laboratory test report from a CPSC-accepted lab, tied to the specific SKU being imported. You should ask for the underlying test report, not just the certificate, and verify the accepting laboratory on CPSC's published accepted-lab list.

Can Amazon file on my behalf?

No. Amazon is not the importer of record on FBA shipments. The seller (or the seller's US-registered entity) is the importer of record, and the filing obligation flows to whoever is on the entry paperwork as importer of record. Amazon provides the destination FBA address but does not assume the importer role.

What if my product falls into a category where I am unsure whether a CPC or GCC is required?

Consult a customs broker or product safety attorney before shipping. The cost of an hour of professional advice is dramatically lower than the cost of a detained container plus per-diem storage fees plus a missed FBA arrival window. CPSC's own [Small Business Ombudsman program](https://www.cpsc.gov/Business--Manufacturing/Small-Business-Resources) also provides free classification guidance for small importers.

Does the eFiling data have to be submitted before the shipment sails, or before it arrives?

eFiling data is submitted alongside the ACE entry filing at the time of import entry, which is at or shortly before the shipment's arrival at a US port. It does not need to happen before the shipment departs the origin port, but the supporting documentation (test report, certificate) needs to be in your possession before you can file, which is why the 90-day pre-import checklist starts before the goods ship.

Are there penalties for filing incorrectly versus not filing at all?

Both create problems. Failure to file for a covered product typically results in the shipment being detained. Filing with false or unsupported information can create additional CPSC enforcement exposure separate from the customs hold, including civil penalties. When in doubt, the answer is to slow down and get the classification right before submitting, not to submit something and hope it clears.