Look up / Does CPSC eFiling apply to de minimis (Section 321) shipments?
Does CPSC eFiling apply to de minimis (Section 321) shipments?
Yes. A product that needs a certificate needs it eFiled whatever the shipment is worth.
There is no Section 321 (also known as de minimis) shipment exemption for eFiling.CPSC eFiling FAQ, read 2026-11-10
Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment.CPSC eFiling FAQ, read 2026-11-10
What the regulation says
16 CFR 1110.13(a)(1) names de minimis entries directly: finished products "eligible for the de minimis duty exemption under 19 U.S.C. 1321(a)(2)(C)" must have their certificate data eFiled "at the time of filing the entry".
Who files for a de minimis shipment
For these shipments the rule treats as importer whoever is eligible to make entry under customs rules, which may be the owner, purchaser, consignee or an authorised customs broker (16 CFR 1110.3, restated in CPSC's mail guidance of October 2026).
Mail shipments
CPSC's guidance dated 2026-10-20 says eFiled certificates are required for mail shipments, by Full or Reference Message Set, beginning on 2027-01-20, using the new Entry Type 13.
Sales between consumers
The FAQ says eFiling generally applies when the transaction is commercial, and that a sale of a product from one consumer to another is a commercial transaction. Non-commercial shipments between consumers are outside it.
What happens if nothing is filed
The FAQ says CPSC does not, at this time, intend to ask CBP to deny entry solely because eFiling was missed, and that the entry system initially sends warning messages, not rejections, for missing data. That is CPSC's current stated practice, not an exemption.
What to do
- Look up the HTS code to see whether CPSC flags it.
- If a certificate rule covers the product, give your broker the seven data elements, or enter them in the Product Registry.
- With many products, check the bulk CSV before uploading.