Small shipment question

Does Section 321 or de minimis exempt me from CPSC eFiling?

Shipment value alone is not a safe reason to ignore CPSC certificate and eFiling requirements when a product requires certification.

Audience: Small importers, ecommerce sellers, and buyers using low-value shipment use cases.

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The risk

Many small importers assume low-value shipments are exempt from everything. CPSC's FAQ says there is no Section 321 or de minimis exemption for eFiling when a product requires certification.

Do not treat shipment value as proof that CPSC eFiling is irrelevant.

Confirm whether the product requires certification first.

Ask who will file CPSC import data if the shipment is imported commercially.

A disclaimer filing is different

Sometimes a broker may discuss a disclaimer filing for a product that is not covered. That is different from sending certificate details for a covered product. Do not treat low shipment value as proof that no CPSC data is needed.

Use official CPSC guidance and your broker to decide whether a disclaimer is appropriate.

CPSCReady does not determine whether your product can be disclaimed.

Keep documentation for why the shipment is outside CPSC certificate filing if you are relying on that conclusion.

What to do next

If the product may be CPSC-regulated, prepare the data your broker may ask for or the Product Registry record may require.

Run the am I affected readiness check.

Ask whether the broker wants all certificate details, Product Registry ID numbers, or both.

Collect supplier, lab, rule, and records-contact details before shipment.

Copy-ready assets

Templates you can adapt

Section 321 carrier question

Subject: Section 321 shipment - confirm CPSC eFiling handling

Hi [Carrier/Broker Name],

This shipment may move under Section 321/de minimis, but the product may still be subject to CPSC certificate requirements. Can you confirm whether you can file any required CPSC import data for this shipment?

If yes, do you need all product and certificate details, Product Registry ID numbers, or a specific spreadsheet format?

If no, please confirm whether we need a licensed customs broker or another filing partner before shipment arrival.

Thanks,
[Importer Name]

No-exemption checklist

Before relying on Section 321/de minimis:

1. Confirm whether the product requires a CPC or GCC.
2. Confirm commercial vs personal/gift/sample status.
3. Confirm who is Importer of Record.
4. Confirm who can file CPSC import data if required.
5. Keep source records for any decision to disclaim or treat the product as out of scope.

Mini FAQ

Common questions

Does low value alone make CPSC eFiling irrelevant?

No. Shipment value by itself is not a safe reason to ignore certificate data when the product requires certification.

Should CPSCReady decide whether a disclaimer filing is appropriate?

No. Use official CPSC guidance, your broker, and qualified advisors for that determination. CPSCReady can organize the questions and supporting records.

Next step

Use the readiness check before assuming Section 321 solves CPSC eFiling.

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