If you import from China and sell in the US, here’s something you need to know in the next few days: the CPSC’s mandatory electronic filing rule takes full effect on July 8, 2026 — that date is confirmed, not proposed. At the same time, the CPSC has recently done two related things: withdrawn accreditation from four China-based testing laboratories, and launched a national crackdown on counterfeit certification labels, naming China specifically. Together, these three developments change how much weight — and risk — sits behind “the certificate your supplier gave you.”
1. In two days: CPSC electronic filing becomes mandatory (16 CFR Part 1110)
The old system worked like this: goods arrived at port, and only if Customs happened to spot-check your shipment did you need to produce a paper or PDF version of your CPC (Children’s Product Certificate) or GCC (General Certificate of Conformity). Miss the spot-check, and you cleared without scrutiny. Starting July 8, 2026, that gap closes entirely. Every regulated import requiring a CPC or GCC must have its certificate data submitted electronically through CBP’s ACE system before the goods arrive at port — covering seven core data elements: product identification, applicable regulation, manufacturer information, production/test dates, and testing lab details, among others.
This isn’t a spot-check system anymore — it’s a mandatory gate before entry. Incomplete filings, mismatched data, or no filing at all will get the shipment flagged automatically, potentially leading to detention, clearance delays, and civil penalties of up to roughly $120,000. The scope is broad: toys, children’s products, adult apparel and textiles, battery-containing products, furniture — anything requiring a CPC or GCC, with no value exemption, and samples must be filed too.
As of now, submission is in a voluntary period (before July 8) where errors don’t affect your risk score. If you haven’t started connecting to this system, this is the last window to get it right before it becomes mandatory.
2. Your “compliance certificate” may come from a lab that’s already been delisted
This is the piece most easily overlooked, and the one worth verifying right now. On January 15, 2026, CPSC withdrew accreditation from several China-based testing laboratories after finding they had produced unreliable, or outright falsified, test results. This means: if the certificate your supplier gave you was tested by one of these now-delisted labs, that certificate has been invalid from the date of delisting — even if the document itself looks perfectly normal.
What to do now: check on CPSC’s official site whether the testing lab your supplier used currently shows as “Accepted.” If it shows withdrawn, or you can’t find it, the certificate is void, and you need to require your supplier to retest through a currently accredited lab immediately.
3. CPSC is running a national crackdown on fake certification labels — and named China directly
On May 6, 2026, CPSC announced a nationwide initiative specifically targeting counterfeit safety certification labels. The agency’s statement said these labels are “used to push dangerous foreign-made products into American homes,” and that “many of these products originate overseas, including manufacturers operating in the People’s Republic of China.” CPSC’s acting chairman stated publicly that China accounts for one-third of imports under CPSC’s jurisdiction, but three-quarters of product safety standard violations.
This isn’t just rhetoric — under federal law, it is illegal to sell, distribute, or import consumer products bearing counterfeit certification marks. CPSC is now collecting public input (a 60-day comment period) to evaluate whether stronger enforcement, policy, or regulatory tools are needed. The signal is clear: scrutiny of certificate authenticity is only getting stricter from here, not looser.
4. A distinction worth keeping straight: don’t confuse this with the FCC’s electronics lab ban
If you’ve also heard about a “US ban on Chinese labs certifying electronics,” that’s a separate agency, separate action. The Federal Communications Commission (FCC) voted on April 30, 2026 to bar labs in countries without a mutual recognition agreement with the US — including China — from providing FCC certification (which covers electromagnetic compatibility and radio-frequency compliance) for electronics headed to the US market, with a two-year phase-out. This is distinct from CPSC: the FCC governs the RF/EMC compliance of electronic devices; CPSC governs the general safety compliance of consumer products (lead content, choking hazards, flammability, and so on). If your product involves both electronic functions and general consumer-product risk (say, an electronic children’s toy), you may be subject to both systems — but they’re separate reviews with separate lab requirements, and shouldn’t be conflated.
5. What to do now
- Confirm whether your product requires a CPC or GCC certificate, and if so, start connecting to the eFiling system immediately — don’t wait until the last moment before July 8.
- Verify your supplier’s testing lab’s accreditation status on CPSC’s official site, confirming it isn’t one of the delisted labs.
- Re-verify the authenticity of the certificate itself (model, dates, lab information all matching) — don’t just check for the presence of a certificate as a symbol, especially now that CPSC has explicitly named China and is stepping up enforcement.
- Align data fields with your supplier and customs broker in advance, making sure the Importer of Record information matches the certificate exactly — this is where filings commonly go wrong and get flagged.
The bottom line
In two days, CPSC moves from a spot-check system to a mandatory filing system — no electronic filing, no entry. At the same time, scrutiny of Chinese testing labs is tightening, and the certificate you’re relying on may have come from a lab that’s already been delisted without your knowledge. The move to make now isn’t waiting for a problem to surface — it’s verifying two things immediately: is your lab still valid, and is your electronic filing ready.
Details reflect official CPSC announcements and 16 CFR Part 1110 as of early July 2026, plus public statements regarding lab accreditation and the May 2026 counterfeit-labels initiative. The FCC electronics lab rule is a separate action under a different agency and is referenced only for clarity. Regulatory details and deadlines are subject to change — verify current requirements against official CPSC and CBP sources before acting. General sourcing guidance, not legal advice.