Small importer guide

CPSC eFiling for small importers

Small importers still need a practical way to decide whether they are affected, collect supplier/lab records, and prepare broker handoff data.

Audience: Small importers, private-label operators, marketplace sellers, and first-time U.S. importers.

Start with the affected-shipment questions

Before paying for packet exports, clarify whether the shipment is imported, commercial, new or used/resold, and likely tied to a certificate workflow.

Commercial marketplace orders should not be treated like personal gifts.
Used, resold, refurbished, or overstock products may still require review.
Section 321/de minimis value is not a safe standalone exemption assumption.

Collect the hard-to-get records

The main work is usually gathering data from suppliers, factories, labs, brokers, and forwarders.

Ask suppliers for manufacture date/place, factory legal name, model/SKU, and batch/lot references.
Ask labs for report number, test date, lab address, phone, citations tested, and testing exclusions.
Ask brokers whether Full PGA or Reference PGA is supported.

Prepare a handoff packet

A small importer needs organized, reviewable outputs that can be sent to trade partners.

Full PGA data pack.
Reference PGA identifier pack.
Missing-data checklist and request templates.

Copy-ready assets

Templates you can adapt

Small importer supplier request

Subject: Product and factory details needed before U.S. shipment

Hi [Supplier Name],

Before this product ships to the United States, please confirm the legal manufacturer name, factory address, manufacture date range, SKU/model identifiers, batch/lot references, and whether the materials, components, labels, packaging, age grading, or factory changed after testing.

Please attach the latest test report or confirm which report number applies to this shipment.

Thanks,
[Importer Name]

Small importer broker request

Subject: Confirm CPSC eFiling support for small importer shipment

Hi [Broker Name],

Can you confirm whether you can transmit CPSC Full PGA data, Reference PGA identifiers, or both for this shipment? We are preparing product, citation, manufacturer, testing, lab, records-contact, and Product Registry data before entry.

Please send your preferred format and deadline.

Mini FAQ

Common questions

Does being a small importer change the data needed?

Not necessarily. Small importers often need the same certificate-data fields; the practical challenge is collecting them early enough.

What should I do first?

Confirm import/commercial scope, broker support, test/citation records, and whether Full PGA or Reference PGA is expected.

Next step

Check if your shipment is affected before building your first packet.