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CPSC Hopes to Start 'e-Filing' PGA Message Set Pilot in 2023, Mandate Use by 2025

TUCSON, Arizona -- The Consumer Product Safety Commission aims to begin a pilot program in 2023 with wide participation from importers to test “e-filing” of certificate of compliance data elements, with an eye toward making the PGA message set mandatory in 2025, said Sabrina Keller, deputy director of CPSC’s Office of Import Surveillance, during a panel of the National Customs Brokers & Forwarders Association of America annual conference May 2.

The long-awaited “beta” pilot will be based on a plan the full commission approved in 2020, building on lessons from the CPSC’s “alpha” e-filing pilot in 2016 (see 1701270043). The commission will continue its certificate “registry” approach, and will require all seven of the data elements it required under the alpha pilot, Keller said. CPSC also will limit the scope of the requirements to products filed under about 300 Harmonized Tariff Schedule subheadings, she said.

CPSC hopes to publish a Federal Register notice “next month” on the beta pilot, which it began to develop late last year, Keller said. CPSC will look for 30-50 importers to participate in the test, and hopes for “variety” among participants, she said. The commission also will host a public workshop in fall 2022 to “gather more industry input,” Keller said.

Even prior to the beta pilot's launch, CPSC will run a smaller pilot with nine importers and brokers to advise on the “IT aspect” of e-filing,” Keller said. CPSC then expects its beta pilot to “kick off with active filing in 2023,” while it continues its rulemaking process through 2023 and 2024, she said. “E-filing will be final and effective and mandatory in 2025,” she said.

Keller noted that the data elements CPSC will require with its new PGA message set are not new to importers, who are already required to provide them to the government on certificates of compliance. “The only difference here is that they are electronically filed at the time of entry.”