06/27/2026

CPSC's New eFiling Mandate Starts July 8: What Plush Importers Need to Know

A new US import rule lands on July 8, 2026, and it touches almost every brand bringing plush into the country. From that date, importers of consumer products covered by a federal safety standard must file their compliance certificate data electronically, at the moment of customs entry, through Customs and Border Protection's ACE system. Plush toys are children's products under that rule, so the change applies to them directly.

What is the CPSC eFiling mandate? It is a US Consumer Product Safety Commission rule that requires importers to submit certificate-of-compliance data to CBP at the time of entry, instead of keeping the certificate on file and producing it only when asked. The rule takes effect on July 8, 2026 for most imports, and on January 8, 2027 for goods entering from a Foreign Trade Zone. It does not change which products need to be certified. It changes how and when the certificate data is filed, and it standardizes what that data must contain.

What Changes on July 8

Until now, a plush importer kept its Children's Product Certificate on hand and showed it only if CBP or the CPSC flagged a shipment. Under the new rule, the certificate data has to be transmitted electronically through ACE when the entry is filed, before the goods are released. The CPSC then uses that data to target inspections and to clear compliant shipments faster. There is no exemption for small shipments: the requirement applies regardless of shipment value, including low-value parcels that previously entered under the Section 321 de minimis path.

To prepare the trade for the switch, the CPSC published a list of roughly 600 tariff (HTS) codes in January 2026 that will be flagged for review in ACE from July 8. Toys and other children's product categories are on that list. The list is guidance and will change over time, and products under non-flagged codes can still require a certificate, so classification alone does not settle whether a filing is needed.

What Plush Importers Must File

For each certified plush product, the importer transmits a defined set of certificate data elements through ACE. The core fields:

Product identifier: a unique ID such as a GTIN, UPC, SKU, model number, or serial number, with a description that matches the product to the certificate.
Cited safety rule: each CPSC rule the plush is certified to, such as the ASTM F963 toy standard.
Certifier contact: the party issuing the certificate.
Records custodian: who holds the supporting records.
Manufacturing date and place: when and where the plush was made.
Testing date and place: when and where it was last tested for compliance.
Attestation of compliance: plus any testing exclusions relied upon.

There are two ways to file, and the right one depends on how often the same product ships.

Filing method	How it works	Best for
Full PGA Message Set	All certificate data elements are sent through ACE with each shipment	Importers with a small or changing range of products
Reference PGA Message Set	Certificate data is pre-loaded in the CPSC Product Registry, and a reference ID travels with the entry	The same plush product shipping again and again

Certificates and the supporting test records behind them must be kept for at least five years from the date the certificate was created.

Why Plush Sits Squarely in Scope

Plush toys are children's products, which means each design needs a Children's Product Certificate backed by testing at a CPSC-accepted third-party lab, currently to the mandatory ASTM F963-23 standard plus the CPSIA limits on lead and phthalates. That testing, and the certificate behind it, is exactly what now has to be filed at entry.

The reason the CPSC is tightening the data trail shows up in the recall record. Plush recalls cluster around the same failure modes: detachable plastic eyes and noses, small parts that come loose, and trims a child can pull off and swallow. Recent 2026 recalls include alpaca plush cited for a small-parts violation and clip-on giraffe and llama plush pulled over a choking risk. Detachable plastic eyes and loose small parts are the patterns that recur, and each one is a testing and documentation question as much as a design one.

What It Means for Brands and Importers

The legal duty sits with the importer of record, not the overseas factory. But several of the required fields, the manufacturing date and place, the testing date and place, and the records behind the certificate, come from the factory. A plush program moves through the new rule cleanly only when the factory supplies accurate, current compliance data for every batch and the importer maps it to the right fields before the container sails.

For buyers, the prep is straightforward: lock the bill of materials and supplier list per design, run third-party testing to the destination standard, confirm the certificate carries the required data elements, decide with your customs broker whether to file by Full or Reference message set, and keep the permanent tracking label and records in order. This is the same discipline that already separates a reliable plush supplier from a cheap quote: per-design, per-market testing and a documentation trail that holds up. Our overview of safety and compliance covers how testing and certificates are handled per order, and getting the custom plush built to standard from the first sample is what keeps compliance from becoming a border problem.

The safety requirements a plush toy must meet are unchanged. The difference is timing. The certificate data now has to be filed when the goods enter the country, so importers who keep it current with their factory and file it correctly will clear customs the way the system intends. Those who still treat the certificate as a document to dig up after a shipment is flagged are the ones who will see delays.