How We Work · As of July 8, 2026, certificates stopped being paperwork in a drawer and became entry data. Here’s what changed — and why, if your factory keeps its records straight, none of it needs to slow your project down.
If you import brushes into the United States, your customs broker has probably already asked a question they didn’t ask last year: do you have certificate data for this entry? That’s the CPSC’s eFiling rule arriving in your supply chain. Before anything else, the answer most of our clients need first: this rule changes paperwork, not your project — and the paperwork it demands is data a well-run factory already keeps. What follows is what the rule actually requires, which side of it your brushes sit on, and exactly what we hand you so that none of it becomes your problem to chase.
Imported products regulated by the CPSC must now have their certificate of compliance filed electronically at the time of entry, through CBP’s ACE system — either filed in full with each entry by your broker, or pre-loaded once into the CPSC’s Product Registry and referenced by certificate number shipment after shipment. (Entries from foreign-trade zones follow in January 2027.) One detail worth knowing even if you never touch a form: small parcels are not exempt — shipments entering under the Section 321 de minimis channel (under $800) are covered too.
This is the classification that decides whether the rule touches you at all — and for most brush brands, the news is calm.
Adult cosmetic brushes: the usual answer is nothing to eFile. A standard makeup brush sold to adults is a cosmetic accessory; its regulatory home is the FDA world — the MoCRA territory we’ve covered separately — and it’s generally not subject to a CPSC mandatory standard. No standard, no certificate, no filing. What did change: “no certificate required” is now an active determination your broker acts on, not a silence nobody questioned. It should be written down once and given to your broker — and we support it with the product data that makes it defensible.
Children’s brushes: the certificate world. The moment a brush is designed or marketed for children — a play-makeup set, a kids’ kit, cartoon packaging — it’s a children’s product, and every entry requires an eFiled Children’s Product Certificate (CPC), resting on tests from a CPSC-accepted third-party laboratory: total lead, lead in paint under 16 CFR 1303 — painted wooden handles are tested per paint color — small-parts requirements by age grade, and ASTM F963 where it applies. Note that the fork turns on who the product is for, and marketing moves it as surely as design does.
Look at what the certificate data actually consists of: product identification, applicable rules, the accredited lab, testing dates, manufacturing dates and factory identification, batch records that match the container. Almost all of it originates on the factory floor — which means the difference between “eFiling is boring” and “eFiling is a crisis” is simply whether your factory treats these records as part of the product. We do, as standard:
One thing procurement teams are discovering this year: sample shipments meet the same questions. A courier parcel with development samples rides the same customs channels as your production order — including the small-parcel channel the rule now covers — and a sample stuck in clearance can stall a launch calendar as effectively as a stuck container.
So we treat sample paperwork as part of the sample: clear product identification, intended-market and age-positioning stated, and the supporting data your broker needs to answer the entry question before it’s asked. When you order samples from us for the US market, tell us it’s for the US — the shipment leaves with its answers attached.
Plain honesty about the seam: the certificate and the filing belong to the importer — you, with your broker. The evidence belongs to the supply chain — us. We’re a factory, not a customs broker or a law firm; final classification and filing mechanics sit with your broker and counsel, and the CPSC’s own eFiling FAQ is the primary reference. But everything the filing consumes — the tests, the dates, the records, the identification — is ours to provide, and we provide it without being chased.
Every eFiling problem we can foresee is decided before production, not at the border: whether the product is a children’s product is decided in the brief; whether the paint passes 1303 is decided in material selection; whether the certificate data matches the shipment is decided by whether the factory kept its records. That’s the same discipline as everything else we write about — close the variable while it’s cheap.
If you’re planning a US-bound line — adult, children’s, or samples first — put the market and the age positioning in the brief, and we’ll tell you exactly which tests, which records, and which paper will ride along with your goods. You worry about the brand. The border paperwork is part of what you’re buying from us.
It depends on who the brush is for. Standard adult cosmetic brushes are generally not subject to a CPSC mandatory standard – no certificate, nothing to eFile – though ‘no certificate required’ is now an active determination your broker acts on and should be documented. Brushes designed or marketed for children are children’s products, and every US entry now requires an electronically filed Children’s Product Certificate.
A certificate the importer issues based on testing from a CPSC-accepted third-party laboratory, covering the rules that apply to the product: total lead content, lead in paint under 16 CFR 1303 (painted handles are tested per paint color), small-parts requirements by age grade, and the ASTM F963 toy standard where it applies. Under eFiling, its data elements are filed electronically with every entry.
Yes – shipments entering under the Section 321 de minimis channel (under $800) are covered by the eFiling requirement too. Brands that ship direct-to-consumer parcels or courier samples into the US travel the same road as containerized cargo, which is why sample shipments deserve the same paperwork preparation as production orders.
Product identification, the applicable rules, the accredited testing lab, testing dates, and manufacturing dates and locations – plus the batch reality those records describe. Almost all of it originates on the factory floor, which is why a factory that keeps clean batch and production records makes eFiling routine, and one that doesn’t makes every entry an investigation.
Not if the paperwork travels with the goods. The costs arrive only when data is missing at entry – so we prepare it in advance as standard: written product-classification support for adult lines, CPSC-accepted lab coordination and full report sets for children’s lines, and sample shipments sent with identification, intended market, and age positioning already stated. Tell us the shipment is US-bound, and it leaves with its answers attached.
