Countdown to July 8: Your Top Questions Answered

With the July 8 deadline for CPSC eFiling Phase 2 fast approaching, many exporters to the U.S. market remain uncertain about filing rules, documentation requirements, and system operations. To help businesses prepare with confidence, RTS is running a dedicated Q&A series addressing the most common questions we receive. This week, we bring you Part 3 of our expert knowledge series.

1. How Should Importers Manage Version IDs?

The U.S. Consumer Product Safety Commission (CPSC) encourages importers and their trading partners to develop a Version ID generation and maintenance system that best fits their specific business workflows. A Version ID can be any alphanumeric string, but each string must be unique within a single business account's Primary Product ID. In other words, no two certificates under the same Primary Product ID may share the same Version ID.

Because this uniqueness requirement is enforced at the business account level, importers should be mindful of a potential pitfall: if the same Version ID creation system is used across different Collections with different user groups, trading partners may encounter Version ID conflict errors. Coordinating Version ID conventions across teams and partners is essential to avoid last-minute filing issues.

2. How Do You Delete Certificate Data Saved in Collections?

The Product Registry system does not allow users to permanently delete product certificates from Collections. Instead, the platform supports Archive and Unarchive functions.

Archiving lets you hide outdated or incorrect data from active view without losing access to it. If needed, archived certificates can be restored through the Unarchive function. This approach preserves audit trails while keeping your active collections clean and organized.

3. How Do You Modify Certificate Data Saved in Collections?

If a product certificate has already been certified, importers benefit from a 48-hour editing grace period during which product information can be modified using the same Version ID, without needing to create a new version. Please note that this grace period is subject to change at CPSC's discretion.

However, if the certificate was created more than 48 hours ago, or if it has already been used in a Reference PGA message set within that 48-hour window, importers must create a new version with a new Version ID.

Important: Any modification made within the 48-hour grace period requires the certificate to be recertified. Once recertified, the 48-hour editing window resets.

4. What Is the Difference Between Testing Exclusions and Disclaims?

These two concepts serve fundamentally different purposes in CPSC compliance:

Testing Exclusion Code

Use an Exclusion Code when a product requires a certificate, but under the underlying rule's exemptions, exceptions, or determinations, the product is not required to meet specific performance requirements. For detailed guidance, refer to the CPSC eFiling document library, specifically the Citations, Testing Exclusions, and Disclaims Guidance document.

Disclaimer (Disclaims)

Use a disclaimer when a product does not require a certificate at all. This applies when the product falls outside CPSC jurisdiction, is not subject to any certifiable regulation, ban, standard, or rule, or when CPSC has made an enforcement determination (for example, certain refrigerators and adult apparel). In these cases, importers should complete the appropriate disclaimer in the ACE system.

5. Can You Still Obtain CPC/GCC Files After Completing eFiling?

Yes. After importers or their trading partners complete the electronic compliance data submission through eFiling, importers can continue to export CPC and GCC files from the CPSC Product Registry.

Completing eFiling does not remove or limit your ability to retrieve these documents. You can download them as needed for your records, customs submissions, or partner requests.

Final Compliance Tips

With the Phase 2 eFiling deadline imminent, standardized system operation and accurate rule interpretation are the core foundations of U.S. market compliance. Minor operational errors such as duplicate Version IDs, incorrect exemption declarations, and expired certificate modifications may lead to customs clearance delays, compliance audits, or shipment detention.

We will continue to update in-depth eFiling policy interpretations and operational tutorials in subsequent issues to help export enterprises fully adapt to CPSC’s electronic compliance system and achieve a stable and compliant U.S. market layout.