Shein’s fulfillment model is built around high-frequency, low-value shipments -- the exact shipment profile the CPSC eFiling rule specifically declined to exempt.
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The CPSC eFiling final rule states plainly that de minimis shipments are not exempt -- any product requiring certification must have an eFiled certificate regardless of the shipment’s value. A common assumption ("it’s a low-value package, it won’t get checked") does not hold for CPSC-regulated categories.
A fulfillment model built around fast-turnover, high-volume SKUs multiplies the number of certificates that need to stay current -- lab accreditation windows and certificate expirations are easy to lose track of at that scale.
Whatever documentation your Shein-side account requires is separate from what a customs broker eFiles with CBP. Both need to be current and consistent for the same SKU.
If your compliance process was built around de minimis handling for duty purposes, it may not account for the CPSC eFiling requirement at all. EntryProof’s free checker flags this specific gap category.