Pharma Firms: Time to Check Your Certificates of Compliance

The U.S. Consumer Product Safety Commission (CPSC) continues to move full steam ahead with mandatory electronic filing (eFiling) of safety information about imported consumer products. Because this requirement will take effect on July 8, 2026, for most imports (and January 8, 2027, for foreign trade zones), pharmaceutical companies should promptly review their General Certificates of Conformity (GCC) and update them if necessary. The CPSC requires companies to maintain GCCs, which contain the data that companies will need to comply with the new eFiling requirement.

Below we explain CPSC’s enforcement role for pharmaceuticals, eFiling’s significance, how to create and update a GCC, and steps pharmaceutical companies should take now to ensure they’re not the subject of a CPSC enforcement action.