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Lunarcat

Notice for US Customers:
CPSC eFiling Requirement

A new rule takes effect July 8, 2026. Here is what it means for US customers.

What Is Changing

The US government is introducing a new rule starting July 8, 2026. If you are importing a CPSC-regulated consumer product, you (the importer of record) must electronically submit product safety certificate data to US Customs at the time of entry.

Which Products Are Affected

The requirement applies to finished consumer goods subject to CPSC mandatory safety standards.

Children’s products require a Children’s Product Certificate (CPC).
Certain general-use products require a General Certificate of Conformity (GCC).

If a product requires any of these certificates, honestly there is not much we can do.
Products sold in Japan are made for the domestic market.
In most cases, the CPC/GCC will not even exist, and it would be unrealistic to obtain these from the manufacturers even if it exists.

Risky Categories

We do not know how strictly customs will enforce the rules for shipments.
Items may clear with supporting information and without CPC/GCC, or may be returned or seized.

Please ensure that you can complete eFiling, or at least be prepared to answer all questions from your carrier when they reach out.

The following categories need extreme caution:

  • Toys, plush toys, and dolls: Toys designed primarily for children (~12 years old). This includes battery-operated toys, dolls, and plushies. The line between a children’s toy and an adult collectible is not clearly defined under current CPSC guidance.
  • Children’s clothing and infant products
  • And other products listed on this page

Categories Outside CPSC Jurisdiction

The following product types are not regulated by CPSC and are not subject to this rule.
Please continue shopping with confidence.

  • Acrylic goods
  • Airsoft guns
  • Can Badge (Pin Badge)
  • Clothes for adults
  • Food and consumables
  • Eyeglasses and sunglasses
  • Fountain pen inks and writing supplies
  • Parts of a product
  • Plants and seeds
  • Printed Matter (books, trading cards)
  • Rubber Mat

Probably Okay

  • Collectible figures

Filing Requirements for Safe Categories

Filing is not required for products that do not require a certificate.

CPSC does encourage filing a Disclaim A for products that fall under any of these HS codes. Shipments with compliant filings receive lower risk scores and reduces the chance of inspection.

Nevertheless, our view is that it is very unrealistic to expect individual importers to comply with this documentation requirement. Just ignore it if you don’t mind some customs delay.

Disclaim A applies when:

  • Your product is captured by a CPSC HS code, but falls within CPSC’s jurisdiction with no rule, ban, standard, or regulation requiring a certificate. Examples include hats, scarves, gloves, collectible toys intended for adults, and sport helmets (other than bicycle helmets).
  • Your product is captured by a CPSC HS code but falls outside CPSC’s jurisdiction entirely. Examples include medical products similar to general-use products, and non-consumer industrial equipment.
  • Your product is captured by a CPSC HS code and is a component part intended for further assembly or manufacturing in the US. Doll clothing and bicycle parts are listed as examples of component parts.

When filing a Disclaim A, you must also include an intended use code. Common codes include:

Code Description
100.XXXFor Personal Use as a Non-Food Product
130.XXXFor Consumer Use as a Non-Food Product
155.XXXFor Commercial Assembly as a Non-Food Product
980.000For Other Use (with Intended Use Description)

Our Opinion

If you are purchasing toys, plush toys, dolls, or anything that could reasonably be interpreted as a children’s product, exercise caution until the situation is clear. If you have such items already in storage with us, consider shipping immediately, or wait until the situation becomes clear.

The burden falls on the importer’s side. As your proxy, our advice is to refrain from purchasing the high-risk categories. If you have to ship one of the high-risk categories, please plan to complete the eFiling. Resources can be found on this page.

Please continue shopping categories that fall under Disclaim A.

Postal shipments (Japan Post → USPS) have historically involved less contact with recipients than FedEx. Nothing is guaranteed, but there is a chance that items will be flagged less with Japan Post shipping.

We will be monitoring the situation and provide a further update when things become more clear.

Thank you,

Lunarcat Company

FAQ

Does this affect my order if I’m buying for myself, not reselling?

The noncommercial exemption applies only when a private individual who already personally owns a product ships it as a gift to someone in the US. Standard purchases from Lunarcat are commercial transactions and are not exempt.

Am I safe if I purchase a used product and declare the item as used?

Simply declaring an item as used will not save your life. The used exemption applies only to products manufactured before the CSPC effective date (2008).

My product’s HS code is flagged, but I don’t think it’s regulated. What should I do?

You may file a voluntary Disclaim A. This is not required, but it signals to CPSC that your product falls outside their jurisdiction and can reduce the chance of a hold.

Will parts be regulated?

No. CPSC regulates finished consumer products only. Parts are exempt.

What happens if no certificate is filed for a regulated product?

Your shipment may face delays, holds, examination requests, or in some cases seizure. CPSC does not plan to issue hard rejections initially, but enforcement is expected to tighten over time. Things are unclear at this time.

Can I check whether my specific product is regulated?

Use the CPSC Regulatory Robot.

This notice is for informational purposes only and does not constitute legal advice.
Consult a licensed customs broker or attorney for your specific situation.

Sources

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