Understanding CPSC E-Filing and Children’s Product Compliance

Chemical regulations are only part of the story. In our latest episode, Bob Trimble, Program Manager for Global Restricted Substances at Intertek Assuris, sits down with Anju, an expert in U.S. consumer product safety, to explore how CPSC e-filing is changing the compliance landscape, specifically for children’s products.

From documentation requirements to digital reporting, they unpack the challenges companies face and share insights to help you stay ahead of evolving safety expectations.

Tune in to learn how to simplify compliance and protect your brand’s reputation in a more transparent, data-driven future.

Speakers:

• Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris
• Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

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Transcript

00:14 --> 00:44
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

So welcome to the podcast. This is Bob Trimble, program manager for Global Restricted Substances, in the Assuris group at Intertek and, today we're going to dive into the issues we see our clients having. I typically talk about compliance when it comes to chemicals, but we have a guest today, and I'll let her introduce herself, and she's going to talk about CPSC e-filing and children's products. So, tell us a little bit about yourself, Anju.

00:44 --> 01:02
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Hi, Bob. My name is Anju. I'm a consultant working on the risk strategy and management team at Intertek. I've worked in the world of Quality Assurance for the last 12 years, with a recent focus on product intelligence, mainly with toys and children's products. So, thanks so much for having me here today.

01:02 --> 01:27
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

Ah, looking forward to it. So, we said we'd dive right in. So let's dive right in and give us a brief overview of e-filing with the CPSC. I know we use a lot of acronyms around here so maybe we can expand a little bit on what some of these letters mean when it comes to CPSC and stuff like that. But just a brief overview of e-filing to get us going here.

01:27 --> 01:51
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Okay, sure. So e-filing is a new initiative in the US that was created by the CPSC, which stands for the Consumer Product Safety Commission. So it will allow importers to electronically file their certificate of compliance data for their products with the US Customs and Border Protection in the Product Registry, as opposed to doing physical document checks.

01:51 --> 02:00
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

That sounds expeditious. It says this is something everybody has to do? Or is this voluntary?

002:00--> 02:15
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

So the certificate of compliance is a mandatory requirement for products that are regulated under CPSC. So, the process of checking the data is becoming completely electronic, meaning all importers will need to comply with this new requirement by the deadline. 

02:16 --> 02:21
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

So just to cut to the chase here - Why? Why do they have to do this?

02:22 --> 02:49
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Well, it's mainly being introduced to increase efficiency at the border. Having the compliance documents online will reduce the time and the resources needed to check the products for compliance. This will result in fewer delays and fewer shipment holds, which is a benefit for everyone overall. Also, a more efficient process means more shipments can be checked and verified for safety, meaning less product will be able to bypass the process.

02:49 --> 02:59
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

Okay, so we're automating things and we're actually tightening up everything we're looking at so things aren't slipping through. Do I have that kind of right?

02:59 --> 03:00
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Right. 

03:01 --> 03:22
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

Okay. Good good. So let's talk about who's affected by this. So I deal with a lot of manufacturers, contract manufacturers, original equipment manufacturers. Does this affect the consumer? Does this affect the importer? And. Yeah, let's let's, break it down a little bit as to the different groups that this would affect.

03:23 --> 04:18
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Okay. So e-filing will affect different people throughout the supply chain. This includes manufacturers, importers and brokers, retailers and consumers. Manufacturers will have to ensure that their products are designed and built according to the safety standards that are set out by CPSC while importers and brokers are responsible for bringing the products into the country - which means they must verify the product is compliant and that the proper import process is followed. Retailers and consumers are also affected, but in a more positive way. Since there will be less shipment delays and holds, retailers will be able to work with the importers to better meet their expected timelines. And also, the improved oversight at the border, especially for high risk products, means that a higher confidence in product safety, can be achieved, which is great for consumers too. 

04:18 --> 04:31
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Thanks. So when you're talking about high risk products, I know I have kids, my mind goes right to like children's products. So there are different standards for children's products or, how are we dealing with that when it comes to e-filing? 

04:32 --> 04:52
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Yes. So children's products are one of the most highly regulated groups of products because they affect such a vulnerable group. There are really strict guidelines in place to ensure that the products are safe during normal and reasonably foreseeable use. Children's products and toys have to go through a very rigorous testing protocol to ensure that they're safe before entering the US. 

04:52 --> 05:03
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Do you see your clients starting to prepare for this now? Would this be considered early? Do we want to we want to wait and kind of see how it plays out? Where are we at?

05:04 --> 05:36
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

So the e-filing program is going into effect in less than a year from now, with a target date of July 8th, 2026. So companies should actually start to prepare now. They should become familiar with the program and even take part of the voluntary stage, which is currently in process, to help them prepare for when e-filing does become mandatory. They should also see, if they're new, if their products are even regulated under CPSC, and if they have to meet this new requirement. So they should definitely start looking into it now. 

05:36 --> 05:52
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Okay. So yeah, so it's voluntary at this point. But they can get on the platform, right? So let's just kind of talk through picturing this platform or this portal and the information they're going to have to submit. So who can e-file and how does it work.

05:52 --> 06:43
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Okay. So the platform is called the Product Registry. And it's actually very user friendly. At first the responsible party who's usually the importer or the broker will need to register and make an account with the product registry. Once that account has been set up, it's very simple to upload the product and testing information from the certificate of compliance. 

So they could do this by individually adding each product or bulk uploading the compliance data for multiple products at one time, using an Excel sheet and some companies, including Intertek, have created an API software that can electronically transfer their product certificate data directly to the product registry. So there are multiple options on how to use the product registry. It just depends on the volume and the scope of the products

06:43 --> 06:46
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

What kind of, you mentioned certificates, What kind of data goes into the certificate. 

06:47 --> 07:12
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

So there are a few elements that are mandatory for the certificate of compliance. They include the product ID, the citation codes which could be found on the CPSC website for each product category, the manufacture date, the manufacturer address and name, the product testing date, and the testing lab where it occurred and the point of contact there.

07:13--> 07:44
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

So when I help clients prepare for legislation such as RoHS, the restriction of hazardous substances, or REACH for California Proposition 65, we review their documentation, we review their test reports, we help them identify gaps in their processes so that they have everything they need to confidently place compliant products on the market. How does Intertek help with this e-filing? What can we do and what can’t we do? 

07:44 --> 08:14
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Well, at intertek we can get involved at every step of the process. So we could even start at the beginning and provide guidance if your product falls under CPSC and is regulated and requires the certificate of compliance and what those compliance requirements would be in terms of testing requirements. Also, we can guide clients on what information is needed to navigate the registry, and we could even help them upload their certificate data to the product registry itself. 

08:15--> 08:25
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

So that sounds like you can actually go on the platform and show the client how to use it or use it on their behalf, potentially. Is that correct?

08:25 --> 08:39
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Yeah. So when you have an account with a product registry, you can give different people permissions to log in and even do the uploading for you. So there's really a lot of ways where we can support a client depending on their needs.

08:39 --> 08:46
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

So we've been talking about what they can do and what we can do. What can't they do or what shouldn’t they do? What should they avoid? 

08:46 --> 09:08
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

They should avoid not knowing the correct compliance standards for their products, missing information that's needed for the certificates, trying to upload expired test results and other issues like that. They should just make sure all their information is current and valid, and that they're not missing any of the critical information points in a certificate.

09:08 --> 09:32
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Okay, so they could potentially leverage other tester reports or certificates issued, in other global market access regions if they meet all the requirements. But they should be very familiar with that, or whether that's something we could jump in and say, yeah, A equals B or A doesn’t equals B you need to close the gap on that one a little bit. Do I have that right?

09:32 --> 10:09
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Yeah. So you can leverage existing test reports but they must meet certain criteria. So the testing should be within a certain time frame of when the product is intended to be imported. Testing must also be completed by a third party lab that's accredited by the CPSC. If you're unsure about which labs are accredited, there is a list of approved labs on the CPSC website. And also the limits and the thresholds of certain tests have to match the standards set out by your CPSC. So if your existing test reports meet all of these stipulations, then I don't see why you wouldn't be able to leverage those.

10:09 --> 10:17
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

And if they don't meet something, then if there is an issue, with noncompliance, what happens? What are the risks?

10:17 --> 10:47
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Importers can potentially experience shipment delays at the border or even denial of entry of their products if the required information isn't uploaded to the product registry. So multiple instances of noncompliance can lead to more frequent and thorough inspections by CBP, which would also cause further delays and longer wait times for others. So it's definitely a good idea to make sure that you have all your information and you are familiar with the platform and get everything needed uploaded in time.

10:47 --> 10:58
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

And who can manage this? So what if we're talking about strategy and we're talking about partnering with our clients to do this? Who manages the e-filing? 

10:58 --> 11:19
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

So once the initial account has been set up and completed, anyone can be given permission by the account owner to access that product registry. So the account owner is able to decide what access each participant has and which functions they are allowed to perform. So you can have someone just strictly doing the administrative work for you in terms of uploading that data.

11:19 --> 11:34
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris

Thanks. So I'm going to call this Advice by Anju. I don't know. It just popped into my head. So let's give our clients a couple, you know 2 or 3 little pieces of advice just key takeaways just before we wrap this podcast up Anju.

11:34 --> 11:55
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Okay. So I would definitely say do not wait until the last minute, begin gathering all of this certificate data for the products that are intended to be imported in the next year. Ensure the pertinent information is not missing and that all the data is correct, and consider working with the service provider like Intertek to get prepared and start uploading the data too.

11:55 --> 12:28
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Awesome. So let's just recap that right. Start preparing now. Don't wait. The platform/The portal is available, and even though it's not an official submission yet, our clients can get familiar with it. So they should start early and get going. They should review their certificates on product compliance and make make sure that thresholds are correct. And then once, once again, how can Intertek help put this just at the end of the day when they reach out to us

08:46 --> 09:08
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

We can provide guidance on product compliance testing, creating the certificate of compliance, help navigate this new platform with this new requirement and also help upload the certificate data to the registry as well so we can get involved in any step. Product compliance, product testing, uploading, certificate of compliance data, you name it, we can help you any way you need.

12:08 --> 09:32
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

I appreciate that. Good, good. And last but not least, how do people get in touch with you. 

08:46 --> 13:12
 Speaker 2 – Anju Kang, Consultant – Risk Strategy & Management, Intertek Assuris

Well, you could reach out for help by just sending me an email, which is, ANJU.KANG@intertek.com. 

13:12 --> 13:38
 Speaker 1 – Robert Trimble, Program Manager – Global Restricted Substances, Intertek Assuris 

Awesome. Thank you very much. That wraps it up for today. I know I learned some stuff. I hope other people listening to the podcast learned some stuff as well. And we appreciate everybody's time. Good morning. Good evening and good day. Thank you.