CPSC eFiling PGA Module

 

1. Introduction

Beginning on July 8, 2026, electronic filing (eFiling) of product safety certificate data for Consumer Product Safety Commission (CPSC) regulated imports becomes mandatory. This requirement applies to all commercial entries where the imported product is subject to a CPSC mandatory safety standard.

The KlearNow.AI CPSC eFiling PGA Module allows importers and licensed customs brokers to prepare, validate, and transmit the required CPSC PGA Message Set alongside the ACE entry summary directly from the KlearNow.AI platform.

What this guide covers:

How HTS flags (CP1 / CP2) are displayed and what they mean

How to choose between the Full PGA Message Set and the Limited Message Set for Pre-Registered Products

Required data elements for the Full PGA Message Set, including product codes and party information

Step-by-step workflow within the KlearNow.AI platform

 

Note: This guide covers the initial release of the CPSC eFiling module. Screenshots and field labels may be updated in subsequent releases. KlearNow.AI | CPSC eFiling PGA Module | User Guide Effective July 8, 2026

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2. Regulatory Background

CPSC’s eFiling mandate is implemented under the Consumer Product Safety Improvement Act (CPSIA) and operates through CBP’s Partner Government Agency (PGA) Message Set framework within ACE. When a shipment’s HTS code is associated with a CPSC-regulated product, CBP will flag the entry and require the applicable PGA data before release.

The official CPSC guidance document and the full list of approximately 600 affected HTS codes is published at:

CPSC Guidance and HTS List for eFiling of Electronic Certificates (April 2026)

Importers are responsible for eFiling the certificate data whenever required, even if the HTS code does not appear on the CPSC list. The list is intended to assist the trade community in understanding when CBP will coordinate with CPSC to flag specific HTS codes.

Note: The trade community is also encouraged to review CPSC’s 1USG Messaging guidance. Any entry with an eFiled certificate (a CPSC PGA Message Set) will be subject to the 1USG Messaging process.

3. HTS Flags: CP1 and CP2

Within the KlearNow.AI platform, each tariff line is automatically evaluated against the CPSC-monitored HTS code list. Where a match is found, the system will display whether a Disclaim is optional or not. Flag Code	Status	Meaning
CP1	May Be Required	The HTS code is in the CPSC-monitored list. CPSC data may be required depending on the product. Importer should assess whether a certificate applies. DISCLAIM OPTION WILL BE DISPLAYED.
CP2	IS Required	CPSC eFiling is mandatory for this HTS code. A PGA Message Set must be included with the entry or the shipment will not be released. Disclaim option will not be displayed.

 

4. Likely-Affected Product Categories

The following product categories represent the most likely affected product types, as identified in the April 2026 CPSC guidance document. HTS codes within these categories account for approximately 600 of the flagged codes. This list is not exhaustive — other HTS codes may also require eFiling.

Product Category	HTS Chapter(s)
All-Terrain Vehicles (ATVs)	87
Bicycle Helmets	65
Bicycles	87
Button Cell & Coin Batteries	85
CB Antennae	85
Carpets and Rugs	57
Carriages and Strollers	87
Child Chairs	94
Cigarette & Multipurpose Lighters	96
Clothing	61, 62, 65
Drywall	68
Fireworks	36
Gates and Enclosures	39, 44, 73
Imitation Jewelry	71
Infant Sleep Products	94
Lawn Mowers	84
Matchbooks	36
Mattresses	39, 63, 94
Other Children's Furniture	94
Pacifiers	39
Poison Prevention Packaging	24, 36
Shoes	64
Toys	32, 34, 85, 95

 

5. Choosing a Filing Approach

When a CP1 or CP2 flag is present and CPSC eFiling is applicable, trade must select one of two approaches:

5.1 Full PGA Message Set

All Certificate of Compliance data is submitted at the time of entry. This is the default approach and is required unless a valid Product Registry reference is available.

Use this approach when:

The product has not been previously filed in the CPSC Product Registry, OR

The entry contains a new product configuration, OR

The previously registered certificate has expired or is no longer valid

 

5.2 Product Registry Reference PGA Message Set

Only a reference to previously entered Certificate of Compliance data is filed at the time of entry. The reference links to an existing record in the CPSC Product Registry.

Use this approach when:

The product was previously filed in the CPSC Product Registry with a valid Certificate of Compliance, AND

The product configuration, applicable standards, and lab testing have not changed, AND

The registry record is current and has not expired

Note: If there is any doubt about whether the registry record is still valid and current, file the Full PGA Message Set.

 

6. Full PGA Message Set — Required Data Elements

The Full PGA Message Set requires the following categories of data. Sections 6.1 through 6.3 describe each in detail.

6.1 Product Identification Codes

At least one product identification code must be provided. The three available product code types are described below. Trade may provide two or all three identifiers for a single product line. EDI Record	Qualifier Field	Allowed Values	Associated Number Field
PG01	Globally Unique Product ID Qualifier	SRV or AI	Globally Unique Product Identification Code
PG02	Product Code Qualifier	SKU	Product Code Number
PG07	Item Identity Number Qualifier	MN, SE, RN, or ALT	Item Identity Number

 

6.2 Required Parties

Each Full PGA Message Set must include the following parties:

Manufacturer (MF) — Required

The entity that manufactured the product. One Manufacturer party is required on every Full Message Set. Provide the full legal name and address.

Lab / Testing Entity — Required (one of three options)

Each Full Message Set requires at least one lab entity. The three options are: Code	Entity Name	ID Required?	Additional Requirements
ITL	Independent Third Party Lab	Yes — 4-digit CPSC Lab ID	CPSC-Accepted Testing Laboratory accredited for children's product safety rules. Must reference the official Lab ID number.
LAB	Laboratory (Non-CPSC Accepted)	No	Provide address of the test location in PG19 & PG20. Provide contact information in PG21.
NOL	No Lab Testing Required	No	Use for testing exclusions. The applicable exclusion must be identified in the subsequent PG60 Message.

 

7. Filing CPSC Data in KlearNow.AI

The following steps outline the workflow for completing CPSC eFiling within the KlearNow.AI US Customs Brokerage Platform.

1	Open the Entry and Locate Flagged Lines Navigate to the entry summary. Lines flagged with CP1 or CP2 will be highlighted. Click the CPSC icon on a flagged line to open the PGA Filing panel.

 

2	Select Filing Approach Choose Full PGA Message Set or Product Registry Reference. If a valid registry record exists, enter the registry reference number. Otherwise, proceed with the Full Message Set.

 

3	Enter Product Identification Code(s) Provide at least one of PG01 (Globally Unique ID), PG02 (SKU), or PG07 (Item Identity). Enter the qualifier and the corresponding code value.

 

4	Add Manufacturer Party Enter the Manufacturer (MF) name and address. This party is mandatory on every Full Message Set.

 

5	Add Lab Entity Party and Citation(s) Select ITL, LAB, or NOL. Provide the required supporting information (Lab ID for ITL; address/contact for LAB; exclusion details for NOL). Add at least one Citation referencing the applicable CPSC safety rule.

 

6	Validate and Transmit Click Validate to run the pre-submission compliance check. Resolve any flagged errors. Click Transmit to submit the PGA Message Set to ACE alongside the entry.

 

Note: The KlearNow.AI validator checks for mandatory field completeness, qualifier code correctness, and lab ID format (4-digit numeric for ITL). Submissions that fail validation will not be transmitted.

 

8. Quick Reference Summary

Mandate Date

July 8, 2026 — CPSC eFiling becomes mandatory for all applicable imports arriving on or after July 8, 2026

 

CP1 Flag

CPSC data MAY be required — importer must assess applicability

 

CP2 Flag

CPSC data IS required — entry will not release without a valid PGA Message Set

 

Filing Options

Full PGA Message Set (all data at entry) OR Product Registry Reference (link to prior registry record)

 

Product Codes

At least one of: PG01 (SRV / AI), PG02 (SKU), PG07 (MN / SE / RN / ALT)

 

Required Parties

Manufacturer (MF) always required. Lab entity (ITL, LAB, or NOL) always required with Citation.

 

Citation	Each lab entity must reference at least one CPSC safety rule, ban, standard, or regulation.
CPSC HTS List	~600 HTS codes across 23 product categories — see CPSC April 2026 guidance document for full list.

 

9. Support and Resources

For questions about your CPSC eFiling obligations or the KlearNow.AI platform, please contact:

KlearNow.AI Support: Please submit a support ticket through our Customer Support team via Support - KlearNow.AI

CPSC Trade Guidance: https://www.cpsc.gov/eFilingDownload PDF

CPSC HTS & Guidance Document: Download PDF

CPSC Citation Guidance: https://www.cpsc.gov/s3fs-public/eFiling-Citation-Testing-Exclusion-Disclaim-Guidance-v3.pdf?VersionId=v8ye0UNlYRjruDoNnRG_gbessaJhpzN3

CBP ACE PGA Message Set Reference: Available through the ACE CATAIR documentation portal

This document will be updated as CPSC issues further guidance. The most current version is always available in the KlearNow.AI Help Center within the platform.

 

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