The Consumer Product Safety Commission released clarification regarding the July 8 eFiling deadline, primarily on trade parties, which refers to a stored entry of manufacturer, laboratory or point of contact information that has been added within a business account. CPSC advised against creating duplicate trade parties and adding a CPSC-accepted laboratory to the product registry.
"We know many importers are not fully ready. Some have started the CPSC Product Registry process but are still working through it. Others have thus far chosen not to register in the Product Registry. As a result, customs brokers can expect to be entering the certificate data into the full CPSC message set for many of their importer clients -- at least initially," the National Customs Brokers & Forwarders Association of America wrote in guidance released July 2.
CPSC said once a trade party's information has been added to a business account, the same trade party shouldn't be added again. If a trade party's information changes, users should create a new trade party entry.
Importers should reference the existing CPSC-accepted laboratory list, as CPSC-accepted laboratories should never be added to the product registry by users. Only the laboratory's four-digit CPSC ID should be provided. CPSC clarified that the intended use of a laboratory test sub-record within a certificate is that each laboratory will refer to citations tested by that laboratory.
The registry allows users to stack different certificate versions on top of each other for the same primary product by using the "update" option. A product's certificate history is readily accessible in one coherent chain, allowing CPSC to understand the product's history.
When users aren't providing updated certifications or recertification on an existing certificate, they're not expected to use the certificate update feature and can instead create new certificates, though they won't be recognized as having a common history.
CPSC clarified that the getImportStatus function informs users on the processing state of an import, but doesn't provide insight into the success or failure or error states for certificates. However, getImportLog will provide any relevant error codes or messages. CPSC said there's a short lag after an import has been initiated where getImportStatus may not have a valid status, and recommended waiting at least two seconds after initiating an import before calling getImportStatus.
CPSC also said users can only provide certificate data in the English language.
Users should avoid sending out duplicate invitations when inviting trade partners to collaborate.
The current product registry API enforces a 5,000 character limit per certificate, which didn't pose challenges during the voluntary period. The product registry API and CSV Upload can handle bulk uploads ranging up to and beyond 10,000 products, though beyond that isn't recommended. The product registry implements rate limiting restrictions limiting interactions to five per second.
In a member alert, the National Customs Brokers & Forwarders Association of America said that certificate data must be transmitted for CP2-flagged Harmonized Tariff Schedule codes, and no disclaims are allowed with CP2 flags. Failure to provide the certificate e-filing will only trigger a warning for now, but the lack of data will impact the importer's risk score for future targeting and thus increases the likelihood of a shipment being held and examined.
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