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Why do apparel importers need to be concerned about the upcoming Consumer Product Safety Commission (CPSC) final rule on eFiling Certificates of Compliance (COC)? The simple answer is that when the final CPSC rule is published, likely this year, the CPSC will flag virtually all apparel Harmonized Tariff Schedule (HTS) classifications for a Children's Product Certificate (CPC) or a General Certificate of Conformity (GCC). The flagging means that importers will need to provide, and brokers will need to send data to CBP’s Automated Commercial Environment (ACE) with the CPSC required data elements even for styles that are exempt from certification.
ACE will require the filing of the COC data elements, either CPC data elements for children’s products or GCC data elements for on-children’s products, with imports of all apparel that is flagged for CPSC. More than 95% of the 2,000+ 10 digit HTS classifications for apparel in Chapter 61 and 62 are flagged “CPC Required” or “CPC or GCC may be required.”
HTS classifications that are exclusively for boys’, girls’ or infants wearing apparel, including children’s and infant’s sleepwear, are flagged as requiring the CPC. The broker must file seven required data elements for each style or SKU imported.
HTS classifications that include wearing apparel for boys’ and men or girls’ and women along with HTS classifications that are exclusively for women or men are flagged as possibly requiring the CPC or the GCC. The importer must determine if the CPC is required, the GCC is required or if neither is required and must communicate the appropriate data elements to their broker.
If the style is children’s apparel (including children’s sleepwear) the broker must file seven required CPC data elements for each style or SKU imported.¹
If the style is adult apparel the broker must file seven required GCC data elements for each style or SKU imported unless the style is exempt from testing.²
If the style is adult apparel and is exempt from testing under 16 CFR 1610.1(d)(1) or (2) the broker must file three required disclaimer data elements for each style or SKU imported.³
¹Style number and description, each applicable CPSC product safety rule, importer certifying compliance, contact information for the recordkeeper, date and place of manufacture, date and place of testing and third-party laboratory information.
²Style number and description, each applicable CPSC product safety rule, importer certifying compliance, contact information for the recordkeeper, date and place of manufacture, date and place of testing and third-party laboratory information.
³Style number and description, intended use code and disclaimer qualifier code (always B for apparel).
There are three methods for filing the COC:
The importer may decide to have their broker file the full Partner Government Agency (PGA) message set in ACE.
The importer may decide to file most of the data in the CPSC Product Registry and provide their broker with certificate identifiers (Certifier ID, Product ID, and Version ID) to be filed in ACE
If the importer determines that the style does not require a COC, the importer can have the broker file the disclaimer data elements in ACE.
Please contact me at tom@tomgouldcustoms.com if you would like assistance implementing procedures to meet these new CPSC eFiling rules.
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