CPSC Intended Use Codes & Disclaim Codes for eFiling (2026)
A source-backed reference for choosing and documenting Intended Use Codes, Disclaim A, and Disclaim B in the CPSC eFiling Disclaimer PGA workflow.
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- VelaCert Editorial Team
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Last verified: September 2026. Information is based on current CPSC and CBP guidance. Users should confirm the latest official requirements for their specific product. This reference does not determine jurisdiction, applicable rules, certificate obligations, testing exclusions, enforcement discretion, or filing eligibility.
Direct answer
A CPSC intended use code identifies a product's intended use in a CPSC eFiling Disclaimer PGA Message Set. A CPSC disclaim code explains why certificate data is not supplied: A means the product is not regulated by CPSC for the filing reason; B means data is not required under CPSC guidance. When a disclaimer is filed, CPSC requires an intended use code.
CPSC Intended Use Codes vs. Disclaim Codes — At a Glance
The Intended Use Code describes what the product will be used for. The Disclaim code states why certificate data is not being provided. They are separate PG01 data elements and must be supported by the same product and transaction facts.
| Field / Code | Meaning | When it is used | Required / conditional | Example | Official source |
|---|---|---|---|---|---|
| Intended Use Code | Identifies the product’s intended use in ACE | Required whenever a CPSC Disclaimer PGA Message Set is filed | Mandatory in a Disclaimer Message Set | 130.006 | CPSC CATAIR V2.5, pp. 12–13; CBP Appendix R |
| Intended Use Description | Free-text explanation for an ‘other use’ code | Used when the code is 980.000 | Conditional | Product-specific explanation of the other use | CPSC CATAIR V2.5, p. 12 |
| Disclaim A | Product is not regulated by CPSC for the filing reason represented | No certificate is required because no certificate-requiring CPSC rule applies, the item is outside CPSC jurisdiction, or another current Disclaim A scenario applies | Conditional; disclaimer filing itself is optional | A | CPSC CATAIR V2.5, pp. 10–12 |
| Disclaim B | Certificate data is not required per CPSC guidance | Only for current CPSC enforcement-discretion scenarios | Conditional; must use Intended Use Code 130.006 | B | CPSC CATAIR V2.5, pp. 11–12 |
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What is a CPSC Intended Use Code?
A CPSC Intended Use Code identifies the intended use of the imported product in the ACE PGA Message Set. CBP Appendix R constructs each code from a three-digit base code and a three-digit subcode. The complete value is reported, including the period—for example, 130.006.
The current CPSC CATAIR marks Intended Use Code as mandatory in a Disclaimer PGA Message Set. CPSC's guide lists code families commonly used with disclaimers, but says that list is guidance and other Appendix R codes may be used. Select the complete code that accurately describes the documented use; the code itself does not establish whether Disclaim A or B is legally appropriate.
Official source: CPSC eFiling Implementation Guide V2.5, pages 12–13; CBP Appendix R, Part 1.
What is a CPSC Disclaim Code?
A CPSC Disclaim Code records why certificate data is not being supplied for an entry line associated with a CPSC-identified HTSUS code. The available PG01 values are A and B. A disclaimer does not repair an incomplete certificate and does not replace a testing exclusion.
The Disclaimer PGA Message Set is optional. CPSC says filers may submit it when no certificate is required and encourages filing because it may improve the entry line's risk score. If a disclaimer is submitted, both the disclaimer value and an Intended Use Code are required.
Official source: CPSC CATAIR V2.5, pages 10–13; CPSC eFiling FAQ, “Are importers required to transmit Disclaim PGA Message Sets?”
Intended Use Code vs. Disclaim Code
The Intended Use Code describes the use; the Disclaim Code describes the no-certificate basis. A consumer-use value such as 130.006 does not, by itself, mean Disclaim A or B. The filer must separately establish the current CPSC basis for the disclaimer.
Intended Use answers
What is this product intended to be used for? The answer is encoded using the complete Appendix R value.
Disclaim answers
Why is certificate data not being provided? The answer must fit current Disclaim A or Disclaim B guidance.
Disclaim A
Use Disclaim A only when no certificate is required and the facts fit a current CPSC Disclaim A scenario. CATAIR V2.5 identifies products within CPSC jurisdiction for which no certificate-requiring rule applies, products outside CPSC jurisdiction, and qualifying component parts that are not intended for sale to or use by consumers as finished products.
The current guide also places upholstered furniture under Disclaim A when 16 CFR part 1640 is the only applicable rule and the required certification label is present. Other applicable requirements can still trigger a GCC or CPC. V2.5 also identifies personal-use products exported for repair and then reimported, and noncommercial gifts sent from one consumer abroad to another U.S. consumer, as Disclaim A scenarios.
Official source: CPSC CATAIR V2.5, pages 10–11. Version 2.5's change log states that Disclaim A scenarios were updated.
Disclaim B
Disclaim B is for a limited CPSC enforcement-discretion scenario in which a rule applies but CPSC does not require a certificate. Current CATAIR V2.5 names adult wearing apparel claiming an exemption under 16 CFR 1610.1(d)(1) or (d)(2), and household refrigerators displaying an appropriate safety certification mark indicating compliance.
When Disclaim B is filed, CATAIR V2.5 requires Intended Use Code 130.006. Appendix R defines that code as “Consumer product intended for People aged 13 Years or Older.” Do not apply Disclaim B to a different product merely because the phrase “data is not required per agency guidance” seems broad.
Official source: CPSC CATAIR V2.5, pages 11–13; CPSC Citations, Testing Exclusions, and Disclaims guidance, pages 3–4; CBP Appendix R, page 13.
What does “data is not required per agency guidance” mean?
It is the CATAIR description of Disclaim B, not a catch-all value for unavailable data. It means CPSC has identified an enforcement-discretion situation where the product is within its jurisdiction and a rule applies, but CPSC guidance does not require a certificate for that specific scenario.
It does not mean that a filer may omit required certificate data, substitute a disclaimer for a late test report, or turn an uncertain regulatory decision into Disclaim B. Product-specific judgment must come before the code selection.
When is Intended Use Description required?
Intended Use Description is required when the Intended Use Code is 980.000, “For Other Use.” The description should state the actual intended use clearly enough to explain why the other-use code was selected. It should not be used to conceal uncertainty or simply repeat a vague commercial description.
Official source: CPSC CATAIR V2.5, page 12; CBP Appendix R, page 20.
Current Intended Use Codes referenced in CPSC guidance
CPSC CATAIR V2.5 lists the following code families as guidance for Disclaimer PGA Message Sets. The XXX notation is not a filing value; select and report the complete code from current CBP Appendix R. CPSC says other Intended Use Codes may also be used.
| Code or family | CPSC guidance description | Filing note |
|---|---|---|
| 081.XXX | For Human Medical Use as Medical Device | Listed by CPSC as a code family that may be used with a disclaimer. |
| 090.XXX | For Military Use as a Non-Food Product | Use the complete Appendix R code that matches the actual use. |
| 100.XXX | For Personal Use as a Non-Food Product | The product and transaction facts still determine whether a disclaimer is appropriate. |
| 130.XXX | For Consumer Use as a Non-Food Product | CPSC lists this family for disclaimers except 130.001–130.005; Disclaim B specifically requires 130.006. |
| 155.XXX | For Commercial Assembly as a Non-Food Product | Relevant to a documented component-for-assembly scenario when the completed code matches the end use. |
| 940.XXX | For Compassionate/Emergency Use of a Non-Food Product | Confirm the complete code in current Appendix R. |
| 970.XXX | For Export | Confirm that the actual transaction matches the selected Appendix R code. |
| 980.000 | For Other Use | Requires an Intended Use Description in the CPSC Disclaimer PGA Message Set. |
Source status: CATAIR V2.5 was published by CBP on June 22, 2026 and is listed as the current CPSC implementation guide. CBP's current Appendix R attachment carries Change 2 dated November 23, 2022.
Decision table: Certificate vs. Disclaim A vs. Disclaim B
Use this crosswalk to organize an already-reviewed compliance decision. It does not decide whether a rule applies or whether a product qualifies for enforcement discretion.
| Certificate requirement | Additional condition | Result | Guardrail |
|---|---|---|---|
| A CPSC rule, ban, standard, or regulation requiring certification applies | No claimed testing exclusion | Certificate data: Full PGA or a certified Product Registry record referenced through Reference PGA | Do not use a disclaim merely because certificate data is missing. |
| A certificate is required, and a testing exclusion applies to a particular requirement | The product remains subject to another requirement that requires certification | Certificate plus the applicable testing exclusion code | A testing exclusion is part of the certificate workflow, not Disclaim A or B. |
| No certificate-requiring CPSC requirement applies, or the item is outside CPSC jurisdiction | The facts fit current CPSC Disclaim A guidance | Disclaim A may be filed with the matching Intended Use Code | The Disclaimer PGA Message Set is optional; confirm the product-specific basis. |
| The item is a component for manufacture or assembly, not for sale to or use by consumers as a finished product | The facts fit the component scenario in CATAIR V2.5 | Disclaim A may be filed with the matching Intended Use Code | Do not use this path for a component that is itself imported as a finished consumer product. |
| A CPSC rule applies, but CPSC expressly exercises enforcement discretion so no certificate is required | The product is one of the limited current Disclaim B scenarios | Disclaim B with Intended Use Code 130.006 | Do not extend Disclaim B to a product not named in current CPSC guidance. |
| The certificate or disclaimer basis is unclear | The product facts or applicable rule analysis is incomplete | No automated answer | Confirm the current CPSC and CBP requirements with the responsible compliance professional or agency before filing. |
Worked examples
Adult collectible toy with no certificate-requiring rule
CPSC's guidance lists collectible toys intended for adults as a Disclaim A example. If the reviewed product facts support that conclusion, the filing may pair Disclaim A with the complete consumer-use code that matches the intended age; for a product intended for people 13 or older, Appendix R defines 130.006. The code does not replace the underlying product assessment.
Adult wearing apparel under the named flammability exemption
For adult wearing apparel that actually qualifies under 16 CFR 1610.1(d)(1) or (d)(2), current CPSC guidance identifies Disclaim B and CATAIR V2.5 requires Intended Use Code 130.006. Do not generalize this result to all apparel or to a product subject to another certificate-requiring rule.
Component for assembly into an adult-use finished product
A component imported for manufacture or assembly, and not for sale to or use by consumers as a finished product, is a current Disclaim A scenario. If its documented use is commercial assembly into a consumer product for people 13 or older, Appendix R provides 155.006. Confirm both the component facts and complete code before filing.
Certificate required, with a testing exclusion for one requirement
If another rule still requires certification, the filer prepares the certificate and records the applicable testing exclusion code. CPSC states that a testing exclusion is used only when a certificate is required for another rule, ban, standard, or regulation. This is not Disclaim A or B.
How this looks in practice
The regulatory decision and the document-to-data task are separate. A responsible compliance professional confirms the applicable certificate or disclaimer path; the operations team then turns the supporting records into consistent filing data.
- Step 1Official code, test report, or certificate
- Step 2Structured product and filing fields
- Step 3Human review and missing-field validation
- Step 4Reviewed data prepared for the selected filing workflow
VelaCert automates this document-to-data step: it extracts candidate compliance fields, keeps them connected to product and source records, and presents them for human review. It does not decide which laws apply, whether certification is required, or whether Disclaim A or B is available.
Common mistakes
| Mistake | Better control |
|---|---|
| Using Disclaim B for any optional or missing field | Disclaim B is a narrow enforcement-discretion path, not a general ‘data unavailable’ value. |
| Treating a testing exclusion as a disclaim | Keep the certificate and submit the applicable testing exclusion code when a certificate remains required. |
| Sending only a three-digit base code | Appendix R says to report the full base code plus subcode, such as 130.006 or a .000 code when no listed subcode applies. |
| Using 980.000 without a description | Add the required Intended Use Description when ‘For Other Use’ is selected. |
| Assuming an HTS flag proves certification is required | The flag is a screening signal; determine the product-specific CPSC requirement and use the appropriate certificate or disclaim path. |
| Relying on an old Beta guide | CATAIR V2.5 changed current Disclaim A scenarios. Verify the Document Library and CBP CATAIR page before filing. |
Related CPSC eFiling references
- CPSC eFiling Citation Codes explains how certificate requirement codes differ from Intended Use and Disclaim codes.
- CPSC eFiling Data Requirements lists the data importers should organize for Full and Reference PGA workflows.
- CPSC Product Registry Data Dictionary provides field formats and conditional rules for Registry data.
- Managing CPSC Test Reports covers evidence organization across products and suppliers.
Official CPSC and CBP sources
- CPSC eFiling Implementation Guide (CATAIR) V2.5— U.S. Customs and Border Protection
- Citations, Testing Exclusions, and Disclaims (Version 3)— U.S. Consumer Product Safety Commission
- eFiling Frequently Asked Questions— U.S. Consumer Product Safety Commission
- Product Registry Frequently Asked Questions V1.4— U.S. Consumer Product Safety Commission
- Appendix R: Intended Use Codes for ACE— U.S. Customs and Border Protection
- eFiling Document Library— U.S. Consumer Product Safety Commission
Frequently asked questions
What is a CPSC Intended Use Code?
A CPSC Intended Use Code is the complete ACE code for the product’s intended use: a three-digit base code plus a three-digit subcode. In a CPSC Disclaimer PGA Message Set, the intended use code is mandatory. CBP Appendix R defines the full code list, while the current CPSC CATAIR identifies codes commonly used for CPSC disclaim scenarios.
What are CPSC Disclaim Codes A and B?
Disclaim A means the product is not regulated by CPSC for the purpose represented by the message: for example, no certificate-requiring CPSC rule applies, the item is outside CPSC jurisdiction, or a current CPSC Disclaim A scenario applies. Disclaim B means certificate data is not required under CPSC guidance because CPSC is exercising enforcement discretion for a narrowly identified product scenario.
Is a CPSC Disclaim PGA Message Set required?
No. CPSC’s current FAQ and CATAIR describe the Disclaimer PGA Message Set as optional. CPSC encourages its use because it may improve the entry line’s risk score. If a disclaimer is filed, however, the PG01 disclaimer value and an Intended Use Code are required.
Which Intended Use Code is required with Disclaim B?
The CPSC eFiling Implementation Guide V2.5 requires 130.006 when filing Disclaim B. CBP Appendix R defines 130.006 as a consumer product intended for people aged 13 years or older. CPSC limits Disclaim B to the specific enforcement-discretion scenarios stated in its current guidance.
When is Intended Use Description required?
The Intended Use Description is required when Intended Use Code 980.000, For Other Use, is provided. Use a clear, product-specific description rather than repeating a generic commercial description.
Is a testing exclusion the same as a CPSC Disclaim?
No. A testing exclusion is used when a certificate is required but testing to a particular requirement is excluded, exempted, or otherwise not required under that rule. A Disclaim Message Set is used only when no certificate is required for the product under the applicable CPSC guidance.
What does ‘data is not required per agency guidance’ mean?
That is the CATAIR description for Disclaim B. It refers to a product within CPSC jurisdiction and subject to a rule, ban, standard, or regulation for which CPSC is exercising enforcement discretion so that no certificate is required. It is not a general option for incomplete certificate data.