Introduction
For online sellers importing into the United States, a lab report can look like the finish line. According to PortCert, a service that prepares CPSC certificates and eFiling documents, it is often just the starting point. In this interview, the PortCert team explains what typically goes wrong when a product already has a lab report, what sellers miss about eFiling, and the one decision they should not rush.
PortCert was recently included in a Peekwire article on CPSC eFiling services. The team agreed to answer three questions in writing. Their responses, edited only for clarity, are below.
When a Lab Report Isn't Enough
Peekwire: When a seller comes to you with a product that already has a lab report, what has usually been missing from it for the CPC or GCC to hold up?
"A report can be perfectly fine as far as it goes. What breaks a certificate is what it doesn't cover."
The gaps tend to fall into four categories. First, parts that were never sent to the lab. "The classic gap: the fabric is tested, but not the screen print, the zipper pull or the snaps." Textiles with no treatment other than dyes are excluded from lead testing, but a print usually is not. Accessible metal parts also need a lead test unless they are made of an exempted metal such as certain stainless steels. On children's shoes, PortCert says to look at the sole, the buckle and the logo.
Second, the lab itself may not be accepted for that specific test. "CPSC accepts labs rule by rule and test method by test method. A lab can be accepted for lead and not for flammability, and ISO/IEC 17025 accreditation alone is not CPSC acceptance." If the factory owns the lab, it must be accepted as a firewalled lab.
Third, the report may not match the product being imported. A different paint color, a component from a new supplier, or a report that was more than a year old when the goods were made can break the link between the test and the shipment. The periodic testing interval for most children's products is one year.
Fourth, the certificate needs facts that a lab report does not contain. "A lab report describes the sample, not the production run: the month and place of manufacture usually have to come from the factory."
PortCert's approach is to read every report line by line against what the product is made of, part by part, before writing a certificate.
eFiling: Who Does What, and What Actually Certifies
Peekwire: What keeps coming up in eFiling that the guidance sellers find on their own leaves out?
Three practical points come up repeatedly. The first is role confusion. "Guides say 'eFile your certificate.' In practice, the importer certifies and remains responsible for eFiling, and the customs broker usually transmits the data with the entry." The broker can send the full certificate data every time, or, if the certificate is in CPSC's Product Registry, three identifiers: Certifier ID, Product ID and Version ID. The Registry does not talk to CBP's system, so the importer has to give those IDs to the broker.
The second is that uploading a file is not the same as certifying it. "Unless whoever imports the file has certifying rights and ticks 'Certify valid certificates upon importing?', each record lands as 'Awaiting Certification' until someone certifies it." For a Reference filing, the certificate must be entered and certified before the entry is filed.
The third is that the HTS list is a flag, not a decision. "CPSC's list of about 600 codes flags goods likely to be regulated, and it isn't complete. If no CPSC rule requiring a certificate applies, no certificate is needed, even if the code is listed. If one does apply, a certificate is needed even if the code isn't listed."
Dates also move. In October, CPSC moved eFiling for goods sent by international mail from October 22, 2026 to January 20, 2027. Anything written before that may show the old date. Meanwhile, certificate data for mailed goods already has to be in CPSC's Product Registry before they arrive.
PortCert checks every Registry file against CPSC's own CSV guide before it goes out. A recent order involved 25 certificates in one upload with zero import errors. The company also offers a free HTS checker covering all 589 codes on CPSC's October 2026 list, with CPSC's CP1 or CP2 flag for each.
The Decision That Shouldn't Be Rushed
Peekwire: If you could stop sellers from deciding one thing too quickly when they are getting a product ready to file, what would it be?
"Deciding which certificate they need from the age label."
A "14+" or "for adults" label does not settle the question. CPSC weighs four factors: the seller's reasonable statement of intended use, the packaging and marketing, how consumers see the product, and CPSC staff's Age Determination Guidelines. Small sizes, cartoon motifs or play value can make it a children's product for ages 12 and under, whatever the box says.
That decision changes everything that follows. A children's product needs a Children's Product Certificate, backed by tests from a CPSC-accepted lab except where a testing exclusion applies, and by periodic retests. A general-use product needs a General Certificate of Conformity only when a CPSC rule applies to it.
"So settle that first: who the product is for, what it's made of, part by part, and which rules apply. Then order tests."
PortCert offers a free check: tell them what the product is, who it is for and what it is made of, send any reports, and within one U.S. business day they will say which tests it needs and which it is excluded from, before any lab fees are paid.
What PortCert Does
PortCert prepares CPSC certificates (CPC or GCC), the Product Registry file and the broker sheet for small importers and online sellers. The service costs a flat $79 per certificate, with lab fees separate, and has a two U.S. business day turnaround. More information is available at portcert.com.
For sellers navigating CPSC eFiling requirements and Product Registry rules, the interview points to a consistent theme: the certificate is only as strong as the part-by-part review behind it.