INTERNATIONAL TRADE LAW
How to Comply With US Import Safety Rules
Import safety compliance means proving — before your goods reach the border — that they meet the US product-safety rules enforced by agencies like the CPSC, FDA, and EPA, with CBP holding shipments that fall short. The specific rules depend on the product, but the pattern is consistent: identify the agency, meet its testing and certification requirements, and keep the records that prove it. This guide covers the agencies you are most likely to encounter and what each expects.
Who Regulates Product Safety at the Border
CBP enforces safety rules but does not write them. The substantive requirements come from partner government agencies, each covering a slice of the marketplace:
| Agency | Products | Core safety requirement |
|---|---|---|
| CPSC | Consumer products, children’s goods | Certificate of conformity based on testing |
| FDA | Food, drugs, cosmetics, devices | Registration; prior notice for food |
| EPA | Chemicals, pesticides, engines | Registration and conformity declarations |
| NHTSA / DOT | Motor vehicles and equipment | Federal safety-standard conformance |
| USDA | Meat, poultry, plants | Inspection and permits |
When more than one agency regulates a product, you must satisfy each. Which agencies apply is closely tied to import licensing, so the two analyses go together.
CPSC: The Most Common Consumer-Product Rules
If you import consumer goods, the Consumer Product Safety Commission (CPSC) rules under the Consumer Product Safety Improvement Act (CPSIA) are the ones to know. They turn on a single distinction: is the product intended for children 12 and under?
- General-use products that are subject to a CPSC safety rule require a General Certificate of Conformity (GCC). The importer or manufacturer certifies compliance based on a test or a reasonable testing program — third-party lab testing is not generally required.
- Children’s products require a Children’s Product Certificate (CPC), and the testing must be done by a CPSC-accepted third-party lab. Testing covers the applicable rules — for example, lead content, phthalates, and the ASTM F963 toy-safety standard.
A practical change is coming: CBP and CPSC are moving to mandatory electronic filing (eFiling) of certificates for regulated imported products, with the requirement beginning July 8, 2026. Importers of regulated consumer and children’s products should be ready to file certificate data electronically at entry. For more on the agency’s rules, see our overview of CPSC regulations.
FDA: Food, Drugs, Cosmetics, and Devices
The FDA regulates a large share of imports. For food, importers generally must ensure the foreign facility is registered and must submit prior notice of the shipment to the FDA — filed through CBP’s ACE system — so the agency can target inspections. Drugs, medical devices, and cosmetics carry their own registration, listing, and labeling requirements. FDA-regulated goods that arrive without the right filings are routinely detained at the border.
The Compliance Pattern That Works
Across agencies, the importers who clear smoothly follow the same playbook:
- Identify the rules that apply to your specific product and its intended use.
- Build testing and certification into sourcing — require suppliers to meet the standard and document it.
- Hold the certificates and test reports ready to present at entry.
- Keep records so you can prove compliance during a CBP request, an FDA detention, or a recall.
- Have a recall plan in case a defect surfaces after entry.
Putting this in writing is the heart of an import compliance program, and it sits inside the larger import process from classification through clearance.
Frequently Asked Questions
What is the difference between a GCC and a CPC? A General Certificate of Conformity covers regulated general-use products and can rely on the importer’s own reasonable testing. A Children’s Product Certificate covers children’s products and must be based on testing by a CPSC-accepted third-party lab.
When does CPSC certificate eFiling become mandatory? The CPSC eFiling requirement for regulated imported consumer and children’s products begins July 8, 2026. Confirm the current scope before your next shipment.
Do I need to notify the FDA before importing food? Yes. Importers generally must submit prior notice of imported food to the FDA, filed through CBP’s ACE system, in addition to other facility-registration requirements.
What happens if my product fails a safety requirement? CBP can detain or refuse the shipment, and the regulating agency can pursue penalties, recalls, or forfeiture. Catching the issue before entry is far cheaper than fixing it after.
Importing a regulated product? Reidel Law Firm helps importers identify the safety rules that apply and prepares flat-fee import/export compliance memos with direct attorney access. Get an import compliance memo →
