Is a CPSC disclaim message required?

No. CPSC's FAQ says Disclaim PGA Message Sets are not required, though CPSC encourages them because they may improve an importer's risk score.

What is the difference between Disclaim A and Disclaim B?

Disclaim A is for a product captured by CPSC's HTS codes where no rule requiring a certificate applies or the product is outside CPSC's jurisdiction. Disclaim B is for a product where a rule applies but CPSC is exercising enforcement discretion that no certificate is required; its intended use code is 130.006.

Look up / CPSC eFiling disclaim codes

CPSC eFiling disclaim codes

A disclaim tells customs that no certificate is required for a product whose HTS code CPSC flags. It is optional.

No, Disclaim PGA Message Sets are not required.CPSC eFiling FAQ, read 2026-11-10

The FAQ adds that CPSC encourages filing them because it may improve the importer's risk score. Everything below is from CPSC's Citation, Testing Exclusion, and Disclaim Guidance (library date 2026-09-30).

Does a CPSC rule apply?	Is CPSC exercising enforcement discretion?	What to submit	Intended use codes
Yes	No	Certificate with testing exclusion codes	130.001-005 (optional)
Yes	Yes	Disclaim B: data is not required per agency guidance	130.006 (required)
No	n/a	Disclaim A: product is not regulated by this agency	081.XXX, 090.XXX, 100.XXX, 130.XXX (besides 130.001-005), 155.XXX, 940.XXX, 970.XXX, 980.000 (required)

Disclaim A intended use codes

Code	Meaning
081.XXX	For Human Medical Use as Medical Device
090.XXX	For Military Use as a Non-Food Product
100.XXX	For Personal Use as a Non-Food Product
130.XXX	For Consumer Use as a Non-Food Product (besides 130.001-005)
155.XXX	For Commercial Assembly as a Non-Food Product
940.XXX	For Compassionate/Emergency Use of a Non-Food Product
970.XXX	For Export
980.000	For Other Use (with Intended Use Description)

Disclaim A examples in the guidance: adult hats and gloves; collectible toys intended for adults; sport helmets other than bicycle helmets; medical products similar to general-use products; non-consumer industrial equipment.

Disclaim B examples: adult wearing apparel claiming the exemption under 16 CFR 1610.1(d)(1) or (d)(2); household refrigerators that display an appropriate safety certification mark. Its only intended use code is 130.006, consumer product intended for people aged 13 years or older.

Disclaim or testing exclusion code?

CPSC's guidance: "Testing exclusion codes will only be used when a certificate is required for another rule, ban, standard, or regulation." If no certificate is required for the product at all, the guidance points to a disclaim instead. Disclaims are sent in the customs entry by the broker; they are not part of the bulk upload CSV.

The "No Certificate Required" rows

CPSC's citation workbook ends with six entries where compliance is required but a certificate is not:

Code	Subject	CPSC note	Row
`1500.3`	FHSA Labeling	If the only applicable requirement is labeling under the FHSA, compliance is required but certification is not	127
`1500.14(b)(8)`	Art Materials	Compliance is required but certification is not	128
`1500.17`	Certain bans under 16 CFR § 1500.17	Compliance is required but certification is not unless the Commission voted to include the ban in the list of certificate requirements above; see 78 FR 28080	129
`1610`	Adult Wearing Apparel	If meets requirements for the Commission enforcement discretion (81 FR 12587) and no other rules requiring certification apply	130
`1640`	Upholstered Furniture	Statutory and regulatory certificate exemption	131
`1750`	Refrigerator Doors	If meets requirements for the Commission enforcement discretion (84 FR 37767) and no other rules requiring certification apply	132