16 CFR Part 1110 Mandatory eFiling effective July 8, 2026 — every certificate, every entry, verified.

The most rigorous CPSC eFiling compliance pack an importer can use.

CertGuard assembles a documentation-complete certificate and eFiling package — every applicable CPSC rule, every required test report reconciliation, the ACE transmission payload, and the certificate-of-record library — checked against the letter of 16 CFR Part 1110 and CPSIA before a specialist releases it.

Every applicable CPSC rule mapped per SKUTest report reconciliation against each ruleACE PGA message-set payload assemblySpecialist release on every certificate5-business-day SLA
Why compliance fails

A single missing rule or mismatched test report can detain your container.

Starting July 8, 2026, CPSC eFiling requires importers to transmit structured certificate data into CBP's ACE at time of entry for every regulated product. Miss an applicable rule, fail to reconcile a supplier test report, or transmit inconsistent data — and your goods can be detained, you can face civil penalties up to $120,000 per violation, or worse.

Most importers manage this manually, relying on spreadsheets and supplier-provided certificates that may not cover all required rules. The regulatory landscape is dense: CPSIA, dozens of 16 CFR part rules, ASTM F963, age-determination guidance. Gaps hide in plain sight.

CertGuard exists to close that gap with a single, exhaustive standard applied identically to every SKU and entry.

$120K
maximum civil penalty per violation; $17.15M per related series
The benchmark

Measured against the letter of the regulation — rule by rule.

We do not summarize the law and hope. Every certificate is scored against a versioned rule pack tied to the exact text of 16 CFR Part 1110 and the underlying CPSC rules. These are the provisions each pack is held to.

16 CFR §1110.5

Certificate content elements

All required data fields: product identification, applicable CPSC rules, date of manufacture, testing information, importer/manufacturer details — present and consistent, or the pack does not release.

16 CFR §1110.7

eFiling transmission format

The ACE PGA message-set payload is assembled per CBP technical specifications, with correct data mapping and formatting for automated processing.

CPSIA §102(a)(2)

Children's product certification

For children's products, a Children's Product Certificate (CPC) based on third-party testing by a CPSC-accredited lab is required; CertGuard verifies the lab's accreditation and test report coverage.

16 CFR Part 1109

Reasonable testing program

For general-use products, a General Certificate of Conformity (GCC) based on a reasonable testing program is required; CertGuard reconciles supplier test reports against each applicable rule.

16 CFR §1110.3

Rule applicability determination

Every CPSC rule that applies to the product is identified based on its intended use, age grading, and material composition — no rule is assumed inapplicable without documented reasoning.

16 CFR §1110.9

Recordkeeping and production

A certificate-of-record library is maintained with each certificate, supporting test reports, and transmission logs, available for immediate production to CBP or retailers upon request.

How a pack is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human compliance expert reviews every release. That order is never reversed.

01

Compliance Gap Scan

Upload your product specs, supplier test reports, and shipment list. We return a free completeness read: which CPSC rules apply, which test reports cover them, and what is missing.

02

Rule mapping & test reconciliation

As your authorized clerical agent, we classify each SKU, identify every applicable CPSC rule, and reconcile supplier test reports against those rules — flagging gaps or insufficient coverage.

03

Grounded drafting

The certificate (CPC or GCC) is drafted from your validated data and the rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

Rule coverage is verified against the rule pack; test report dates and lab accreditation are checked; ACE payload format is validated; any failure blocks release.

05

Specialist release

A compliance specialist reviews the exception queue and signs the release. High-value or complex products route to attorney review first.

06

Delivery

You receive the pack: certificate(s), ACE transmission payload, evidence log, certificate-of-record library, and entry-specific filing instructions — ready for your customs broker to transmit.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No certificate ships without a human compliance expert signature.
5 days
Standard SLA
From complete intake to released certificate pack.
<1%
Critical-defect target
Tracked against a gold-standard certificate library.
3+
Rule-mapping sources
CPSC regulations, ASTM standards, and CBP ACE technical specs, every applicable file.
Why CertGuard

Built to be the most thorough option an importer has.

Documentation-complete, by design

The deliverable is completeness itself — every applicable rule and test report accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never give legal advice, contact CBP on your behalf, or make regulatory determinations without expert review.

Engagement

Flat fee, per certificate pack. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a cut of any shipment value.

  • A free Compliance Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released certificate pack (CPC or GCC); disclosed pass-through test report fees if needed.
  • Optional fixed-fee attorney review for high-value or complex products.
  • Optional eFiling Continuity Add-on for ongoing entry-by-entry transmission, pre-mapped to your SKU library.
FAQ

Questions, answered precisely.

Is CertGuard a law firm?
No. CertGuard, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for high-value or complex products.
Do you contact CBP or the CPSC on my behalf?
Never. CertGuard is not a customs broker or regulatory representative. We prepare documentation and transmit data as your authorized clerical agent. Your customs broker remains responsible for filing entries and communicating with CBP.
What makes a certificate pack 'complete'?
Completeness is defined by the regulation: all required certificate content elements present, every applicable CPSC rule mapped and reconciled to test reports, ACE payload format validated, and recordkeeping requirements met. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released certificate pack, plus disclosed pass-through costs for third-party test reports if needed. No contingency and no percentage of any shipment value.

See what's missing before it costs you a container.

Start with a free Compliance Gap Scan. Send your product specs, supplier test reports, and shipment list and we'll return a completeness read against every applicable CPSC rule.

Documentation-completeness service · not legal advice · your customs broker files every entry.