CPSC eFiling: Full PGA vs Reference PGA Message Set
A practical decision guide to choosing a CPSC eFiling method, reusing certified Product Registry records, and handling product certificate changes.
- Author:
- VelaCert Editorial Team
- Published:
- Updated:
This resource is for operational guidance and does not constitute legal advice. Requirements should be verified against current CPSC and CBP guidance. The appropriate filing method depends on the product, certificate record, and importer workflow.
Which CPSC eFiling method should you use: Full PGA or Reference PGA?
Use a Full PGA Message Set when you plan to transmit the applicable certificate data with each entry and do not need to maintain that certificate in CPSC’s Product Registry. Use a Reference PGA Message Set when the certificate is already entered and certified in the Registry and the same product certificate will support repeated imports. The broker then transmits the Certifier ID, Product ID, and Version ID instead of the full certificate data. CPSC describes Reference PGA as preferable for recurring imports and Full PGA as suitable for a limited number of products or products not imported repeatedly. If certificate data changes, update the filing data or Registry version before relying on it again.
Current status: eFiling applied on July 8, 2026 for most imported consumer products subject to CPSC certification. For regulated products admitted into a foreign trade zone and later entered for consumption or warehousing, the applicability date is January 8, 2027.
Decision summary
Full PGA vs Reference PGA: quick comparison
Full PGA sends certificate data with the entry. Reference PGA sends three identifiers that point to a certified Product Registry record. Neither method reduces the underlying certificate requirements.
| Decision point | Full PGA Message Set | Reference PGA Message Set |
|---|---|---|
| Where certificate data lives | Prepared for the entry filing and transmitted through the Full PGA Message Set. | Entered and certified in CPSC’s Product Registry before the entry. |
| Data transmitted at entry | The applicable certificate data records required by CATAIR. | Certifier ID, Product ID, and Version ID. |
| Product Registry required? | No. | Yes. |
| CPSC’s stated fit | A limited number of regulated products or products not imported repeatedly. | Repeated imports of regulated products covered by the same product certificates. |
| Repeated imports | Certificate data is transmitted again with each applicable entry. | The same certified record can be referenced repeatedly while its certificate details remain identical. |
| Product or certificate changes | Transmit the current applicable certificate data in the filing. | Update the Registry certificate and use the current Version ID under CPSC’s version workflow. |
| Operational burden | More data is assembled and transmitted at entry time. | More certificate-data setup and maintenance happens before entry; the entry reference is shorter. |
| Data maintenance responsibility | The importer or responsible certifier must keep the source certificate data current for each filing. | The importer must continuously manage Registry users, trade parties, product data, and certificate versions. |
On small screens, swipe the table horizontally. Filing-record details remain subject to the current CPSC CATAIR implementation guide.
What is the Full PGA Message Set?
The Full PGA Message Set carries the applicable product certificate data through the entry filing. CPSC’s current CATAIR guide defines the record structure used to send product identification, certificate type, manufacturer, testing, citation or testing-exclusion, contact, and attestation information.
- 1Product
- 2Certificate data
- 3Entry filing
- 4CBP sends data to CPSC
CPSC says the Product Registry is not required for Full PGA. The importer still needs a complete, current certificate-data package for the broker or filing system at each applicable entry.
What is the Reference PGA Message Set?
Reference PGA points to product certificate data that the importer or an authorized trade partner has already entered and certified in CPSC’s Product Registry. At entry, the broker files three Certificate Identifiers: Certifier ID, Product ID, and Version ID.
- 1Product
- 2Certified Registry record
- 3Three identifiers
- 4Entry filing
- 5CBP sends reference to CPSC
Certifier ID
Identifies the importer’s Product Registry Business Account and remains the same across its Reference PGA filings.
Product ID
The certificate’s Primary Product ID, using GTIN, UPC, SKU, model, serial, registered number, or alternate ID.
Version ID
Identifies the specific version of the certificate stored for that Product ID.
The Product Registry is a stand-alone CPSC repository. It does not communicate automatically with CBP’s ACE system, so the three identifiers still have to reach the broker and the entry filing.
When may Full PGA make more sense?
Full PGA can be appropriate when the importer has a limited number of regulated products, does not repeatedly import the same product, or has not chosen to maintain that certificate in the Product Registry.
- CPSC guidance
The product is imported infrequently or the importer manages only a limited number of regulated products.
- Workflow condition
The certificate has not been entered and certified in the Product Registry, so it cannot yet support a Reference PGA filing.
- Operational consideration
The team can reliably assemble the current certificate data for each applicable entry.
- Operational consideration
The cost of maintaining Registry records would not reduce meaningful repetition in the filing process.
When does Reference PGA make more sense?
CPSC describes Reference PGA as preferable when an importer repeatedly imports regulated products covered by the same product certificates. The complete certificate is prepared once in the Registry, then multiple entries can reference it while the certificate details remain identical.
- The same certified product is imported across recurring shipments.
- Certificate details are stable enough to be referenced repeatedly.
- The importer has a process for certifying and maintaining Registry data.
- The broker can receive and validate the current Certifier ID, Product ID, and Version ID.
Reference does not mean permanent. Reuse is appropriate only while the referenced certificate details remain identical and current.
What happens when product or certificate data changes?
A Reference PGA filing must identify the correct certificate version. When manufacturer, testing, citation, or other certificate details change, update the Product Registry record under CPSC’s current editing and version rules before using it again.
| Change | What to review | Registry implication |
|---|---|---|
| Manufacturer or factory data | Confirm the current manufacturing party, location, contact details, and manufacture date. | Update the certificate information; create a new version when the current CPSC version rules require it. |
| New or updated testing | Confirm the latest relevant test date, laboratory, citations, exclusions, and supporting report relationship. | CPSC’s FAQ uses annual retesting as an example that results in a new certificate version. |
| Applicable citations or exclusions | Confirm that the certificate reflects the current rules, bans, standards, regulations, and testing exclusions relied upon. | Update and re-certify the record; use the resulting current Version ID. |
| Product identity | Confirm whether the shipped product is still the finished product represented by the Primary Product ID. | The Product Registry does not allow the Primary Product ID to be edited. Treat a genuinely different product identity conservatively and confirm the appropriate certificate-record workflow. |
Example: one product imported repeatedly
This illustrative example shows the workflow; it is not a product-specific legal determination.
- 1
First setup
An importer enters Product A’s complete certificate data in the Product Registry, assigns a Primary Product ID and Version ID V1, and certifies the record.
- 2
First Reference filing
The importer gives its broker the Certifier ID, Product ID, and Version ID V1. The broker submits those identifiers in the Reference PGA Message Set.
- 3
Later identical shipments
If the same certificate details still apply, later entries can reference the same certified V1 record instead of retransmitting the complete certificate data.
- 4
Data changes
After new testing or another certificate-data change, the importer updates the Registry record under CPSC’s version process, certifies V2, and supplies the current Version ID for future filings.
What changes when you have 50, 100, or 500 SKUs?
Reference PGA can reduce repeated entry-level certificate submission, but it does not remove the relationships behind each reference. As product counts and supplier relationships grow, maintaining those relationships can become an operational data-management task.
Full PGA vs Reference PGA checklist
Use these prompts to structure an operational decision with your compliance team and broker. They do not replace product-specific CPSC or CBP guidance.
Consider Full PGA if…
- You import a limited number of regulated products.
- The product is not imported repeatedly.
- The certificate is not stored and certified in the Product Registry.
- Your process can deliver the complete current certificate data at entry time.
Consider Reference PGA if…
- You repeatedly import products covered by the same certificates.
- The complete certificate is entered and certified in the Product Registry.
- Your team maintains current product and certificate versions.
- Your broker receives all three current Certificate Identifiers.
Keep the reference data traceable
Organize the records behind each filing method
VelaCert provides a workspace for connecting product versions, factories, testing, certificate records, missing information, and source documents. It does not determine filing eligibility, transmit PGA messages, or guarantee CPSC acceptance.
Official CPSC, CBP & Federal Register Sources
- eFiling Document Library— U.S. Consumer Product Safety Commission
- eFiling Frequently Asked Questions— U.S. Consumer Product Safety Commission
- Product Registry User Guide V3— U.S. Consumer Product Safety Commission
- Product Registry FAQ V1.4— U.S. Consumer Product Safety Commission
- eFiling Quick Start Guide— U.S. Consumer Product Safety Commission
- eFiling API Specifications V4— U.S. Consumer Product Safety Commission
- CPSC eFiling Implementation Guide (CATAIR v2.5)— U.S. Customs and Border Protection
- Certificates of Compliance Final Rule, 90 FR 1800— Federal Register
- Certificates of Compliance correction, 90 FR 45917— Federal Register
Frequently asked questions
What is the difference between Full PGA and Reference PGA?
A Full PGA Message Set transmits the applicable product certificate data with the entry filing. A Reference PGA Message Set transmits the Certifier ID, Product ID, and Version ID for a certificate already entered and certified in CPSC’s Product Registry. Both methods support the same certificate obligation; they differ in how the filing references the certificate data.
Do I need the CPSC Product Registry to use Reference PGA?
Yes. Reference PGA depends on a completed and certified product certificate in the CPSC Product Registry. The Registry supplies the Certifier ID, Product ID, and Version ID used in the reference filing. CPSC says the Registry is not required for a Full PGA Message Set.
Can the same Product Registry record be used for repeated imports?
Yes, when the same product certificate details remain identical. CPSC says a Product Registry certificate can be referenced repeatedly for multiple shipments of the same product. The importer must still confirm that the referenced product and certificate version remain current for each filing.
What happens if certificate information changes?
The Product Registry record must be updated. Current CPSC guidance provides a limited editing grace period after certification; after that period, or once the certificate has been used in a Reference PGA filing during that period, a new Version ID is required. The updated certificate must be certified, and the current identifiers must reach the filing workflow.
Is Reference PGA better for companies with many SKUs?
It can reduce repeated entry-level submission when the same registered certificates support recurring imports. SKU count alone does not decide the method. The importer also needs reliable Product ID and Version ID mapping, current certificate data, and a process for product, manufacturer, testing, and citation changes.
Does Reference PGA eliminate the need to maintain compliance records?
No. Reference PGA changes how entry filings point to certificate data; it does not remove the duty to keep the Product Registry certificate accurate or retain supporting product and testing records. CPSC places ongoing Product Registry data management responsibility on the importer.