Which products actually need CPSC eFiling?

Not every product an importer sells requires a CPSC certificate at all, and not every certificate requires third-party testing. This guide walks the finished-goods list, the Amazon and Shein-specific triggers most private-label sellers actually hit, and the exemptions that save real money on testing.

The default rule: certificates are required for any product subject to a CPSC rule

Section 14 of the Consumer Product Safety Act, at 15 U.S.C. 2063 on congress.gov, requires that every manufacturer or importer of a consumer product subject to a CPSC-enforced rule, ban, standard, or regulation certify the product's compliance in a written certificate. "Subject to a CPSC rule" is the key phrase. If your product is not covered by any of the ~40 CPSC rules maintained under Title 16 of the Code of Federal Regulations on ecfr.gov, no certificate is required (though other agencies may impose their own; a cosmetic goes to FDA, not CPSC).

The two certificate flavors, one more expensive than the other

Children's Product Certificate (CPC): mandatory for any product primarily designed or intended for children 12 or younger. Requires third-party testing at a CPSC-Accepted Third Party Testing Lab per 16 CFR Part 1107 on ecfr.gov. Testing cost typically ranges $400–$2,500 per SKU per material.

General Certificate of Conformity (GCC): mandatory for any non-children product subject to a CPSC rule. Testing can be first-party (the manufacturer's own testing), so out-of-pocket cost can be near zero if the manufacturer already tests to the standard.

The Amazon trigger: 100% of ASINs in scope categories

Amazon Seller Central's Product Compliance workflow is a strict enforcer. Any ASIN classified into a scope category (Toys, Baby, Nursery, Children's Apparel, and dozens of others) is blocked from listing until a valid CPC or GCC is uploaded. Amazon does its own review; a certificate that omits a required 16 CFR Part 1110 field will bounce with an "invalid certificate" reason code. Amazon's policy tracks the CPSC business guidance for marketplace sellers on cpsc.gov and updates whenever CPSC updates a rule.

The Shein / Temu trigger: post-2025 enforcement letters

Beginning May 2025, CPSC sent public compliance letters to Shein and Temu warning that both platforms were selling products to US consumers without evidence of compliance certificates. Both platforms rolled out seller-side CPSC certificate upload requirements over Q3 2025. The public letters live in the CPSC newsroom on cpsc.gov. Private-label sellers on either marketplace should treat CPC/GCC as a listing prerequisite, not a nice-to-have.

The children-primarily test in practice

The single hardest scope question is "is this a children's product primarily?" The CPSC applies a four-factor test from 16 CFR Part 1200 on ecfr.gov: the marketing and packaging, the product's characteristics, whether the product is sold in stores that primarily sell to children, and the age determinations in the Age Determination Guidelines. A dinosaur-themed t-shirt sized adult-M is not primarily for children. The same t-shirt sized 4T is. Get this wrong in either direction and you either overspend on testing or file the wrong certificate type.

Two exemptions worth knowing

Unfinished materials: bulk fabric, unfinished wood, raw plastic pellets shipped to another business for finishing are typically not "consumer products" and don't require a certificate. Once the material becomes a finished good sold to a consumer, the rule applies.

Small-parts exemption for very small runs: does not exist. Section 14 is strict-liability and volume-independent. Do not rely on "I only sell a few" as a defense; CPSC has assessed penalties on sellers with fewer than 500 units sold.

What EntryProof does with the answer

Once you set the product category on a SKU, EntryProof picks the right certificate type, surfaces the exact 16 CFR standard(s) that apply, and prompts you to upload the third-party test report (if CPC) or the first-party evidence (if GCC). Full flow in uploading test reports into EntryProof.

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FAQ

Does my product need a CPSC certificate if I only sell on eBay? eBay's marketplace-liability posture is different from Amazon's, but the CPSA obligation on the importer is identical. Selling channel does not affect the certification requirement.

What about a product I import for personal use only? Section 14 targets commercial consumer products. A personal-use import for household consumption is generally not in scope. Anything you resell, no matter how small the volume, is.

Can I share one CPC across a family of colorway variants? Only if the colorway differences do not introduce new materials or components (a new dye lot in the same fabric is usually fine; a metal-buckle variant vs a plastic-buckle variant is not).

Still stuck? Email support@digitalempireholdings.com or support@digitalempireholdings.com.

FAQ

Does my product need a CPSC certificate if I only sell on eBay?

eBay's marketplace-liability posture is different from Amazon's, but the CPSA obligation on the importer is identical. Selling channel does not affect the certification requirement.

What about a product I import for personal use only?

Section 14 targets commercial consumer products. A personal-use import for household consumption is generally not in scope. Anything you resell, no matter how small the volume, is.

Can I share one CPC across a family of colorway variants?

Only if the colorway differences do not introduce new materials or components (a new dye lot in the same fabric is usually fine; a metal-buckle variant vs a plastic-buckle variant is not).