Small shipment question

Does Section 321 or de minimis exempt me from CPSC eFiling?

Shipment value alone is not a safe reason to ignore CPSC certificate and eFiling requirements when a product requires certification.

Audience: Small importers, ecommerce sellers, and buyers using low-value shipment workflows.

Check if my shipment is affected View sample handoff packet

The risk

Many small importers assume low-value shipments are exempt from everything. CPSC's FAQ says there is no Section 321 or de minimis exemption for eFiling when a product requires certification.

Do not treat shipment value as proof that CPSC eFiling is irrelevant.

Confirm whether the product requires certification first.

Ask who will transmit CPSC PGA data if the shipment is imported commercially.

Disclaim PGA is different

A Disclaim PGA Message Set is a different concept from a certificate-data filing path. Do not confuse a low-risk or non-covered product with a covered product that still needs certificate data.

Use official CPSC guidance and your broker to decide whether a Disclaim is appropriate.

CPSCReady does not determine whether your product may be disclaimed.

Keep documentation for why the shipment is outside a certificate-data workflow if you are relying on that conclusion.

What to do next

If the product may be CPSC-regulated, prepare the data your broker or Product Registry workflow will require.

Run the am I affected readiness check.

Confirm broker support for Full PGA or Reference PGA.

Collect supplier, lab, citation, and records-contact details before shipment.

Copy-ready assets

Templates you can adapt

Section 321 carrier question

Subject: Section 321 shipment - confirm CPSC eFiling handling

Hi [Carrier/Broker Name],

This shipment may move under Section 321/de minimis, but the product may still be subject to CPSC certificate requirements. Can you confirm whether you can transmit any required CPSC PGA data in ACE for this shipment?

If yes, do you need Full PGA certificate data, Reference PGA identifiers from Product Registry, or a specific spreadsheet format?

If no, please confirm whether we need a licensed customs broker or another filing partner before shipment arrival.

Thanks,
[Importer Name]

No-exemption checklist

Before relying on Section 321/de minimis:

1. Confirm whether the product requires a CPC or GCC.
2. Confirm commercial vs personal/gift/sample status.
3. Confirm who is Importer of Record.
4. Confirm who can file CPSC PGA data in ACE if required.
5. Keep source records for any decision to disclaim or treat the product as out of scope.

Mini FAQ

Common questions

Does low value alone make CPSC eFiling irrelevant?

No. Shipment value by itself is not a safe reason to ignore certificate-data preparation when the product requires certification.

Should CPSCReady decide whether a Disclaim PGA is appropriate?

No. Use official CPSC guidance, your broker, and qualified advisors for that determination. CPSCReady can organize the questions and supporting records.

Next step

Use the readiness check before assuming Section 321 solves CPSC eFiling.

Check if my shipment is affected