Shipping to the US and CPSC: what you need to know

You just booked (or tried to book) a US-bound shipment and saw a warning about the US Consumer Product Safety Commission (CPSC). This article explains what CPSC is, whether it affects your shipment, and what to do next.

If you're short on time, jump to Am I actually affected? or reach out to your support — they'll walk you through it.

What is CPSC?

The Consumer Product Safety Commission is the US regulator responsible for keeping unsafe consumer products out of the US market. It covers over 15,000 product types, from toys to lithium batteries to hair dryers.

What changed on 8 July 2026: Any US import of a CPSC-regulated product now requires electronic submission of certification data at customs entry. This is called eFiling, and it's mandatory — not optional like before.

Two types of certificate exist:

• CPC (Children's Product Certificate) — required for products designed or intended for children aged 12 and under. Must be backed by third-party lab testing.
• GCC (General Certificate of Conformity) — required for adult products in specific flagged categories (e.g. flammability of adult sleepwear, lead content in adult imitation jewellery). Self-certification is allowed — no third-party lab required.

If a product doesn't fall under either, we file a Disclaim — a formal statement that no CPSC rule applies. TUNL handles disclaims for you where we can.

Why is TUNL involved?

TUNL is the Importer of Record (IOR) on all TUNL Economy shipments to the US. That means US Customs holds TUNL legally responsible for ensuring your goods meet US import requirements — including CPSC.

But the underlying compliance obligation (product testing, certification, honest classification) sits with you, the exporter. TUNL can file the data on your behalf, but only if your product is genuinely compliant and correctly classified.

On Express (FedEx / UPS): you are typically the Importer of Record. Express carriers are increasingly asking for CPSC data as well, assume they'll enforce it over time even if today's enforcement is patchy.

Am I actually affected?

You'll see the CPSC warning if any HS code on your booking falls into a flagged category. But being flagged doesn't automatically mean you have compliance work to do. Use this quick self-check:

1. Is your product designed or intended for children aged 12 or under?
Examples: toys, kids' clothing, kids' sleepwear, kids' imitation jewellery, kids' art supplies, baby garments.
→ Yes. You'll need a CPC backed by third-party lab testing. This is the hardest CPSC path — see Children's products below.
2. Is your product an adult product in one of these flagged categories?
Examples: adult imitation jewellery, some adult sleepwear, some adult apparel with flammability regulations, adult hats.
→ Yes. You'll need a GCC — self-certified, no lab testing required. See Adult flagged products below.
3. Are your goods adult collectibles, decorative items, festive articles, or pet accessories that happen to share an HS code with a regulated product?
Examples: adult figurines, ornamental dolls, Christmas decorations, wooden decor.
→ Likely no CPSC action needed. These usually qualify for Disclaim A — TUNL files the disclaim on your behalf. But your HS code may be misclassified — please reach out to support for a quick review.
4. Is your product food, cosmetics, supplements, coffee, or tea?
→ CPSC does not apply. These are regulated by the FDA, which is a separate agency with its own rules. If you saw this warning on an FDA-only product, please let us know so we can fix the flag.

Children's products (CPC)

If you ship products designed or intended for children 12 and under, US law requires a Children's Product Certificate backed by third-party lab testing at a CPSC-approved facility.

The hard truth today: there is no CPSC-approved testing lab in South Africa. Merchants have two practical paths:

1. Use a US-based CPSC-approved lab. This is expensive and slow (weeks to months). Suitable if children's products are your primary business.
2. Reclassify if genuinely misclassified. If your product is an adult collectible, ornament, or decorative item that's been assigned a children's HS code by default, support can help you reclassify to a more accurate code (e.g. HS 3926.40 for ornamental articles, HS 9505 for festive articles). This is only appropriate if the reclassification is genuinely correct — not to avoid compliance.

What TUNL cannot do on your behalf:

• Certify your children's product without CPC evidence
• Ship children's products on TUNL Economy without valid CPC documentation

Adult flagged products (GCC)

Some adult products fall under CPSC rules — most commonly:

• Adult imitation jewellery (lead content regulations)
• Adult flammable apparel (sleepwear, some outerwear)
• Adult hats and headwear

For these, self-certification is allowed. You issue a General Certificate of Conformity (GCC) confirming your product meets the applicable US standard. No third-party lab is required for most GCC categories.

How to get started: Download the GCC template, complete it for each of your products, and email the completed template back to support@tunl.to along with any supporting documentation. We'll review your submission and register your products on the CPSC portal under TUNL's Certifier ID so future shipments clear cleanly.

What you need to prepare: Have your supplier's material composition certificate (or MSDS) on hand — this is the easiest supporting document and most established manufacturers can provide one on request. Alternatively, XRF screening results from a local jewellery testing service or scrap metal dealer are inexpensive, quick to obtain, and equally valid. A full lab test is not required for adult GCC products.

What TUNL does for you: Where your product qualifies for an enforcement discretion or narrow-scope exemption, TUNL files a Disclaim B on your behalf — a formal statement that CPSC has indicated it will not enforce the rule in this case (e.g. adult apparel flammability disclaim).

What happens if I ignore the warning?

TUNL Economy: TUNL is the IOR. If we can't file the required certification data, your shipment may be held at our warehouse or at customs. Historically this has meant a manual reroute to Express (at additional cost) or a return to sender. We'd much rather help you avoid this at booking than fix it after the fact.

Express (FedEx / UPS): you are the IOR. Enforcement is currently patchy but growing. If your goods are held at US customs for missing CPSC data, resolution is on you.

FAQ

Q: Do I need to stop shipping to the US?
No. Most flagged HS codes have a clear path forward — adult products with GCC, or Disclaim A for products that share an HS code with regulated goods but don't need CPSC action.

Q: Am I in trouble for shipments I already sent?
No. CPSC enforcement is forward-looking and risk-based. The warning at booking is designed to help you avoid problems on future shipments — not penalise past ones.

Q: I sell adult collectibles but use a "toy" HS code. What should I do?
This is a known case — the fix is usually reclassifying to a more accurate HS code (like HS 3926.40 for ornamental articles). Reach out to support and we can help you through this.

Q: Does this affect my Express shipments too?
The warning appears on any US-bound shipment with a flagged HS code, regardless of service. Express carriers may or may not enforce CPSC data today, but expect them to over time, you should plan for CPSC compliance as a US-market baseline, not a service-specific concern.

Q: I sell cosmetics / food / coffee. Why did I get the warning?
You shouldn't have — those products are FDA-regulated, not CPSC. If you saw the warning on an FDA-only product, please let us know so we can fix the flag on our side.

Q: Where can I read the actual regulation?
The core rule is 16 CFR Part 1110 (electronic filing of Certificates of Compliance). CPSC's own guidance is at cpsc.gov.

Getting help

The fastest way to get an answer specific to your product:

• Whatsapp or email support — email support@tunl.to or whatsapp here.

We're actively working with merchants to review flagged bookings and, where appropriate, reclassify products, prepare disclaims, or route around blocked services. You are not on your own here.

Updated on: 22/07/2026