CPSC eFiling Citation Codes: How to Find and Use the Right Codes

Definition

What is a CPSC Citation Code?

A Citation Code is the compact value used in CPSC eFiling certificate data to identify an applicable rule, ban, standard, or regulation. It is not a broad product-category label. It represents a requirement to which the filer is certifying the identified product.

CPSC's current guidance says each code contains 3–14 characters. In most cases it is based on the relevant Code of Federal Regulations part number and subsection, including special characters where applicable. For products subject to the ASTM toy standard, the applicable ASTM section numbers are used. CPSC requires every applicable section to be listed.

Where Citation Codes appear in the CPSC eFiling workflow

The confirmed requirement does not change between filing channels, but its technical representation does. Teams should store a normalized code set and then format it for the selected workflow.

For the operational difference between sending full certificate data and referencing a certified Registry record, see CPSC Full PGA vs. Reference PGA.

How to find the Citation Codes that apply to your product

Do not begin by searching a spreadsheet for a product name and copying every nearby row. First establish the product-specific compliance scope; then translate the confirmed requirements into current eFiling codes.

1. 1

   Identify the exact finished product

   Record its intended use, age grading where relevant, materials, construction, product version, and manufacturing source. Similar SKUs can have different applicable requirements.

2. 2

   Determine the applicable requirements

   Have the responsible compliance party evaluate the product against current CPSC statutes, rules, bans, standards, and regulations. CPSC’s CPC and GCC rule pages and Regulatory Robot can support that review.

3. 3

   Open the current CPSC code workbook

   Use the eFiling Citation and Testing Exception Codes file linked from the official Document Library. CPSC updates the library, so avoid relying on a stale local copy without recording its version date.

4. 4

   Match each confirmed requirement

   Copy the exact code, including subsection punctuation or special characters. For ASTM toy-standard requirements, capture every applicable section required by CPSC guidance.

5. 5

   Reconcile codes with evidence

   Check which test report, exclusion record, or other support corresponds to each requirement, and verify that the evidence covers the same product and version.

6. 6

   Approve and version the set

   Record who confirmed the applicability, the source version used, the review date, and the product/certificate version. Reopen the decision when the product or governing requirement changes.

Do not treat CPSC's published lists as a product-classification engine. The eFiling FAQ states that its HTS, citation, and testing-exclusion lists are guidance rather than all-encompassing lists.

One product can have multiple Citation Codes

A certificate can address more than one applicable requirement. CPSC instructs filers to submit a Citation Code for every rule, ban, standard, or regulation to which they are certifying. A multi-code record is therefore normal when a product's confirmed compliance scope includes several requirements.

Do not collapse the set into a single “primary” code for convenience. In Full PGA, repeat PG60 for each applicable citation. In a Product Registry CSV, separate multiple values with semicolons in the relevant Lab Citation Codes field. In an API payload, the corresponding laboratory object holds an array of citationCodes.

CPSC Citation Codes vs. HTS codes

These codes belong to different systems. Confusing them can produce a bad compliance handoff even when each value is individually valid.

How Citation Codes relate to test reports, CPCs, and GCCs

CPSC's CPC instructions require the certificate to identify each applicable children's product safety rule. Its GCC guidance likewise covers certification to applicable rules for general-use products. Citation Codes carry those confirmed requirements into the eFiling data structure.

Test reports are evidence inputs, not automatic code selectors. They may name regulations, standards, test sections, samples, and results. The responsible party still needs to verify that the report applies to the imported product version, that all applicable requirements are represented, and that the current CPSC code uses the expected format.

For a document-centered workflow, see how to manage CPSC test reports across products and suppliers.

Product Registry, CSV bulk upload, and API considerations

The Product Registry supports manual entry, CSV bulk upload, and API integration. Use the current CPSC template or API specification; do not rename fields or invent a private delimiter convention and expect the Registry to interpret it.

• Manual entry

  Select the exact code-description pair offered by the Registry interface.

• CSV

  A valid certificate needs at least one citation or testing exclusion code. Multiple values in Lab {#} Citation Codes are separated with semicolons.

• Multiple labs

  The template begins with fields for two labs and allows numbered lab-column groups to be added. Keep each lab connected to the citations it addresses.

• API

  Provide citationCodes as an array in the relevant lab object. CPSC’s documented validation includes errors for an unrecognized or missing lab citation.

Common CPSC Citation Code mistakes

Disclaim A and Disclaim B are optional message-set paths described by CPSC for defined no-certificate situations. They are not “missing Citation Code” values and should not be used to bypass unfinished certificate preparation.

Citation Code checklist before handing data to a customs broker

• □The finished product and exact product version are identified.
• □A responsible compliance party has confirmed every applicable CPSC requirement.
• □Each requirement is mapped to the exact current Citation Code from an official CPSC source.
• □Special characters and ASTM section numbers are preserved exactly where applicable.
• □Each code is connected to the supporting report, certificate record, or reviewed exclusion evidence.
• □CPC or GCC type and the responsible certifying entity are confirmed.
• □Testing exclusion codes, if used, are kept distinct from Citation Codes.
• □HTS classification is stored separately and has not been used as the sole compliance decision.
• □The team has chosen Full PGA or Reference PGA and formatted the codes for that workflow.
• □The broker receives the product ID, certificate version, code set, owner, and review date—not an unlabeled spreadsheet row.

Use the broader CPSC eFiling data requirements checklist to prepare product, manufacturer, laboratory, contact, certificate, and broker fields around the Citation Codes.

How to organize Citation Code data across many SKUs

For a few stable products, a controlled spreadsheet may be enough. Across many SKUs, manufacturers, test reports, certificates, and versions, the harder problem is keeping each approved code set connected to the exact product and evidence that support it.

Store the compliance decision separately from the source wording. A useful record includes the normalized code, description, official source and source date, applicability status, reviewer, review date, supporting evidence, product version, and certificate version. When a product or requirement changes, reopen the mapping instead of silently copying the prior code set.

For the broader relationship model, read Managing CPSC Compliance Data Across Multiple SKUs.