[eBay] The US will mandate the submission of electronic certificates for imports starting July 8 (CPSC). Should Japanese sellers be aware of this?

On July 8, a quietly important regulatory change will begin in the United States.

This is the eFiling mandate by the CPSC (Consumer Product Safety Commission). When importing consumer products subject to safety standards—such as toys, children's clothing, home appliances, and bedding—into the US, the previous requirement of simply 'having a certificate of compliance on hand' will be replaced by a mandatory 'electronic filing to the CBP (US Customs and Border Protection) system at the time of customs clearance'.

Why was this system created?

The background to this is the issue of a massive influx of products that do not meet safety standards into the US market via platforms like Temu and Shein.

Toys with lead paint, cheap batteries with fire risks, and children's clothing with hood drawstrings that do not meet safety standards—these products have been circulating by exploiting the loophole of 'we have a certificate (but since it isn't checked, the actual status is unknown)'.

The previous system was reactive. It was a mechanism where certificates could only be checked after Customs stopped a shipment they deemed suspicious. There was no way to know what was coming in beforehand.

With the eFiling mandate, the CPSC will receive import data in real-time and be able to pre-screen suspicious shipments using AI risk assessment. Shipments with proper certificates will face fewer inspections, allowing resources to be concentrated on suspicious ones. In effect, this system functions as a 'border control measure against cheap goods from China'.

What is the impact on Japanese eBay sellers?

In conclusion, there is no direct impact on most Japanese eBay sellers.

In cross-border e-commerce, 'who the Importer of Record (IOR) is' becomes important. When a buyer receives an item as a personal import on eBay, the IOR is basically the buyer themselves. In principle, we as sellers do not have an obligation to provide certificates.

However, caution is required in the following cases:

• Handling children's toys or figures: These are products subject to CPSC regulations, and filing is required regardless of the value.

• Shipping via DHL with DDP (Delivered Duty Paid): If DHL handles customs clearance as the IOR, there is a possibility that they will be required to present certificates in the future.

• Apparel containing children's items: Children's clothing is subject to safety standards.

Furthermore, the CPSC itself has stated that 'for the time being, they will not deny entry solely due to a lack of filing, but will only issue warning messages.' Nothing will be stopped immediately, but it will affect risk scores.

Long-term opportunities for Japanese sellers

What is interesting is that this regulatory change could potentially become a tailwind for Japanese sellers in the long term.

Products made in Japan or distributed in Japan already have strict quality standards. It is easier to prepare certificates, and it will move in the direction of lowering risk scores at customs. Differentiation from 'cheap and low-quality' products will be supported at the regulatory level.

An era may be coming where the reliability of 'Made in Japan / Shipped from Japan' holds more value than ever in the US market.

What to do right now

Honestly, no major action is required right now. Just one point:

Check with the carrier you use (such as DHL) to see how they handle IOR and if anything is required from the seller's side.

I think this is sufficient.

Details of the system can be confirmed on the official CPSC website (cpsc.gov/eFiling). For those selling from Japan to the US on eBay, it is information worth keeping in the back of your mind.