U.S. Consumer Product Safety Commission (CPSC)

CIT Hands Down $3.4M Penalty for Duty Evasion

On July 18, 2025, the Court of International Trade (CIT) granted the government’s motion for default judgment against importer Rayson Global and its owner, Doris Cheng, for negligently failing to pay duties. 

The Case

The government’s case was filed in 2023, alleging that the importers had falsely declared that Chinese-origin goods as Thai origin to evade duties. The government asserted this false declaration avoided payment of ordinary 6% duties, Section 301 duties ranging from 10% to 25%, and 234.51% antidumping duties. 

The government asked the court to impose a penalty for negligence. The penalty amount is twice the loss of revenue or the domestic value, whichever is lower. After the importer failed to answer the complaint (a huge mistake), the U.S. moved for summary judgment.

The CIT granted the government’s motion and ordered the importer to pay a nearly $3.4 million penalty as well as all unpaid duties, taxes, and cash deposits on the unliquidated entries in question.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies are turning to creative or outright illegal strategies to reduce their tariff liability.

These incentives have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount […]

CPSC Approves Final Rule to Implement eFiling for Certificates of Compliance

The CPSC voted unanimously in favor of a Final Rule to implement electronic filing (eFiling) of Certificate information for regulated, imported consumer products.

The new eFiling program will apply to all imported consumer products subject to a mandatory safety standard, including de minimis shipments. Requirements impacting most imported consumer products and those produced domestically will take effect in July 2026.

Background – CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the test with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing the expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at the time of import.

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule implementing the eFiling proposal.

eFiling Requirements

The eFiling rule will impose new requirements for how importers manage product certificate data, not which products require a certificate. Any consumer product that is subject to a CPSC […]

CPSC’s Upcoming eFiling Requirement: What You Need to Know

The Consumer Product Safety Commission (CPSC) is tasked with protecting the public from unreasonable risks of injury or death associated with consumer products. The agency issues and enforces standards, issues product recalls, researches hazardous products, and more. The agency also has the authority to order the detention and seizure of goods that it believes to be non-compliant with CPSC safety regulations.

Beginning in 2025, products regulated by the CPSC may be denied entry into the U.S. unless the importer electronically files a detailed product certification with Customs and Border Protection (CBP).

See a full list of CPSC regulated products here.

CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the text with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at import.

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule […]

CPSC Issues New Safety Standards for Aquatic Toys

The Consumer Product Safety Commission (CPSC) published a Notice of Proposed Rulemaking to make the safety standard for aquatic toys more stringent. The primary product targeted in the rule is neck floats which have been reported to pose a serious drowning risk to young children. The rule establishes several testing and performance requirements for these products to ensure the highest level of safety.

Conditioning

The rule would require producers of these products to subject them to conditioning procedures to ensure their durability. These include exposing the products to various temperatures, chlorine and salt water environments, and ultraviolet light.

Minimum standards

To safeguard against unintentional submergence and restraint system failure, the rule proposes additional minimum standards.

Buoyancy Requirements

The Commission is proposing to require that all neck floats demonstrate a minimum upward buoyancy equal to or greater than 30 percent of the expected weight capacity. Additionally, the rule would require that inherently buoyant neck floats to not lose more than 5 percent of their initial buoyancy after being submerged for a 24-hour period.

Restraint Systems

To reduce the likelihood of a restraint system failure on a neck float, which can result in a child slipping through the product, the new rule Commission proposes requirements for the release mode of the fastening mechanism, and overall mechanical integrity of restraint systems.

Marking, Labeling, and Instructional Requirements

In the notice, the CPSC noted that the existing safety messaging for neck floats has  limited effectiveness for preventing the submersion hazard. The rule requires new on-product warnings that include:

  • A description of the hazard;
  • […]

CPSC to Begin Voluntary Stage of eFiling

The Consumer Product Safety Commission (CPSC) is actively recruiting up to 2,000 importers to participate in voluntary eFiling. 

What is eFiling?

In November 2022, the CPSC launched a beta pilot test of an eFiling initiative. The initiative allows importers of regulated consumer products to file electronically with CPSC and Customs and Border Protection (CBP) certain data elements from a certificate of compliance.

The goal of the eFiling process is to expedite targeting of shipments that put people at risk, but also allow importers to establish a good history of safety and to move their products more quickly through the ports.

CPSC anticipates that full implementation of eFiling will occur in or around 2025.

How to Get Started with eFiling

Importers must transmit Message Set data into CBP’s Automated Commercial Environment (ACE) system at the time of entry. There are two options to accomplish this:

Full PGA Message Set: The importer provides their broker with the full product certificate for the imported product and the broker files it in the CPSC PGA Message Set. This is recommended if the importer imports a limited number of regulated consumer products or does not repeatedly import the same product. 

Reference PGA Message Set: The importer pre-enters the certificate data into the CPSC Product Registry and then provides their broker with certificate identifiers to be filed in the PGA Message Set.. This option is preferable if the importer repeatedly […]

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