Amazon FBA sellers importing products subject to the CPSC Product Registry rule must complete a compliant eFiling before their inbound shipment leaves the origin port, not after Amazon receives it. Waiting until after Amazon's fulfillment center inbound-inspection flags a missing registration means your entire shipment can be quarantined, held at Amazon's expense, and sometimes destroyed with no recovery. This walkthrough covers the FBA-specific version of the eFiling flow, since the timing and importer-of-record questions are different from a merchant fulfilling from their own warehouse.
Step 1: Confirm the product is actually in scope
Not every FBA product needs a CPSC eFiling. The rule applies to products in specific CPSC-regulated categories, children's toys, all-terrain vehicles, cigarette lighters, children's sleepwear, and a growing list documented in the CPSC's Product Registry final rule text on federalregister.gov. Use our free CPSC readiness checker to check your product against the current in-scope list before spending time preparing an eFiling for a product that does not need one. Products marked as "not in scope" for the Registry may still need other CPSC compliance (like a General Certificate of Conformity), but do not need a Registry eFiling specifically.
Step 2: Identify the importer of record
The single question that trips up most FBA sellers: for Amazon FBA shipments, are you the importer of record, or is Amazon? The answer is almost always you, the seller, not Amazon, Amazon's Global Selling program is explicit that Amazon does not act as importer of record for FBA inbound inventory unless you specifically enroll in the Amazon Global Logistics (AGL) program with importer-of-record services turned on. This matters because CPSC eFilings must be submitted under the importer of record's name and address, and getting it wrong voids the filing. The CPSC's Regulated Products Handbook on cpsc.gov walks through the importer-of-record definitions CPSC applies for enforcement.
Step 3: Gather the required documentation
A compliant CPSC Product Registry eFiling requires seven pieces of information that must all be assembled before you start the submission form, since the form times out after 30 minutes of inactivity. You need: the product's HTS code (find the correct HTS code using CBP's HTS lookup guidance if you do not already have it), the CPSC product category code, the manufacturer's legal name and full address, the test lab that issued the product's compliance certificate along with the certificate number and issue date, the country of origin, the total quantity in the shipment, and the anticipated port and date of entry into the United States.
Step 4: Prepare the manufacturer certificate
If your product is imported from an overseas manufacturer, you also need a signed General Certificate of Conformity (GCC) or Children's Product Certificate (CPC) from that manufacturer, referencing the specific compliance test report. The certificate must list your company as the importer, not Amazon, and must be signed within the past twelve months. A certificate signed for a previous production run does not automatically cover a new run of the same product, CPSC's own guidance in CPSC Regulatory Robot output on cpsc.gov treats each production run as a separate compliance event, and a certificate more than 12 months old is treated the same as no certificate at all for enforcement purposes.
Step 5: Submit before the shipment leaves origin port
The eFiling must be accepted (not just submitted, accepted) before your ocean or air freight leaves the origin port. A submitted-but-pending filing does not clear the shipment for U.S. entry. Practically, this means submitting at least 3-5 business days before your freight forwarder's scheduled departure, since first-time submissions often come back with a request for corrections that can take 24-48 hours to resolve. Use our CPSC readiness checker before submitting to catch the most common completeness issues.
Step 6: Save the acceptance record for your Amazon inbound shipment
Once accepted, save the acceptance record (a PDF and a filing ID) somewhere your team can retrieve it. If Amazon's inbound inspection later questions the shipment, you can produce the filing ID and CPSC acceptance date on demand, which typically resolves the hold within 24 hours. Without that record, an Amazon inbound hold can extend to weeks and in some cases result in Amazon disposing of the shipment at your cost under their Unsuitable Inventory policy.
What happens if your shipment is already at Amazon and unfiled
If you discover after shipping that a CPSC-required eFiling was never made, the safest path is to submit the eFiling as soon as possible and immediately contact Amazon Seller Support to flag the shipment. Amazon's response is inconsistent, sometimes the shipment is allowed to continue after retroactive filing, sometimes it is quarantined pending disposal. Never attempt to relabel or reroute a non-compliant shipment inside Amazon's network; that becomes a separate fulfillment-policy violation on top of the compliance issue.
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FAQ
Can Amazon file the CPSC eFiling on my behalf? No, unless you are enrolled in Amazon Global Logistics with importer-of-record services turned on. Standard FBA sellers are always their own importer of record for CPSC purposes.
How long is an accepted eFiling valid? The filing is tied to a specific shipment, not to your product line. Each new inbound shipment of the same product requires its own filing, even if the product itself has not changed.
What if my product spans multiple HTS codes? File separately for each HTS code. A single filing cannot cover multiple HTS codes even if the underlying products are related.
Does CPSC ever waive the pre-shipment filing requirement? No. Post-arrival filings can sometimes clear a specific shipment retroactively at CBP's discretion, but this is not a waiver of the requirement itself, and repeat late filings accelerate CPSC scrutiny of future shipments.
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