CPSC e-Filing Pilot to Include 'Batch Filing' of Multiple Certificates in Registry

Filers participating in the upcoming Consumer Product Safety Commission pilot on electronic filing of certificates of compliance will have a “batch filing” option that will allow them to upload multiple certificates at once into a “certificate registry” directly from their internal systems, said Carol Cave, CPSC director of import surveillance, during a March 26 webinar.

Like other users of the certificate registry, the filers would then be able to reference their certificates in the registry using an identifier on entry documentation, absolving them of the task of inputting all ten certificate data elements for every line with a certificate requirement on every entry. Batch filers would likely get auto-responses when data entry issues are identified, such as when one of the certificates lists a third-party laboratory that isn’t accredited to test the certified product, said Cave.

Pilot participants that don’t want to use the batch filing option would still be able to benefit from the certificate registry approach by manually filing their certificates of compliance, said Cave. A web-based application maintained by CPSC for entering certificate data will allow filers to input, maintain and manage certificate info, featuring drop down menus to assist filers with data entry, she said.

CPSC is running the pilot to test a May 2013 proposal to require product safety compliance certificates be filed at entry, instead of being provided on demand to the agency (see 13051018). Trepidation over new burdens and liabilities on the trade community prompted the pilot program and the streamlined certificate registry approach (see 1411100043 and 1503120069). The pilot will also test the option of filing all ten certificate data elements required by CPSC’s proposed rule at the entry line level, CPSC officials have said.

The pilot program is currently scheduled to begin in February, and will last three to six months, said Cave. A Federal Register notice detailing the pilot and requesting volunteers is on its way "in the next month or so," she said. CPSC is holding a series of webinars to gather industry input on the electronic filing pilot. This was the second of three. CBP recently posted slides from the first webinar (here).

The commission is still grappling with several issues raised at the first webinar held March 12, including how it should deal with products or entry lines requiring multiple certificates, such as baby outfits packaged with toys, as well as how FTZ imports should be handled, said Cave at the March 26 outreach session. CPSC is working on mapping HTS numbers to products that require certificates for the purpose of flagging entries in the Automated Broker Interface (ABI), and is mulling over how it should handle HTS numbers that may or may not require a certificate, she said. Another open question is whether the certificate registry should assign identifiers for use on entry documentation, or if companies would rather generate their own certificate identifiers using their internal systems. Cave said CPSC may allow companies to choose either approach.