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CPSC product safety regulations for vintage and secondhand sellers
The U.S. Consumer Product Safety Commission has a new requirement for international sellers shipping to the U.S. Here's what vintage and secondhand sellers need to know — and what's still being worked out
Note: Information in this article is subject to change. The United States Consumer Product Safety Commission (CPSC)’s eFiling requirement is actively being implemented. Guidance from customs agencies, shipping carriers and the CPSC itself is being updated in real time.
Always check directly with your shipper, customs broker or the CPSC for the latest requirements. This article is for informational purposes only and is not legal or compliance advice.
This article explores CPSC product safety requirements as they relate to vintage, antique and secondhand sellers who ship goods into the United States. We focus on what resellers need to know. If you refurbish or upcycle products, there are additional requirements that apply to you.
If you sell vintage, antiques, or secondhand goods and ship to customers in the United States, you may have seen recent news about new product safety filing requirements taking effect on July 8, 2026.
So far, some of these requirements apply to resellers.
What you sell, when it was made and what, if anything, you’ve done to it to make improvements will determine how much information you need to disclose when shipping and whether an exclusion applies.
The new eFiling requirements and CPSC’s existing rules were designed with manufacturers in mind, not the vintage community, so we are still trying to confirm how new requirements and existing rules will apply to vintage goods.
We’ve put together this guide to help you make sense of what’s going on as it stands now.
The basics
What is a CPSC Certificate of Conformity?
A Certificate of Conformity is a document that confirms a consumer product meets the applicable U.S. safety standards set by the Consumer Product Safety Commission (CPSC).
The Certificate of Conformity is issued by the manufacturer or importer of the product, not by the government.
Resellers are considered the importer since they are shipping the product into the U.S. That means resellers may need to file a certificate depending on the product they are sending.
There are two types of certificates:
General Certificate of Conformity (GCC): For general-use consumer products subject to a CPSC mandatory safety standard (such as furniture, helmets, certain electrical products, clothing, and household goods). A GCC is self-certified, based on a testing program you can conduct yourself. For more on testing, scroll down.
Children’s Product Certificate (CPC): For children’s products (products designed or intended primarily for children 12 years of age and younger). Unlike a GCC, a CPC must be based on third-party testing by a CPSC-accepted laboratory.
Not all consumer products require a certificate. The requirement depends on whether a mandatory CPSC safety rule applies to that specific product. As of the time of this writing, CPSC has released 600 Harmonized Tariff Schedule (HTS) codes of products that will require a certificate, but there may be more once the eFiling rule comes into effect.
These certificates were always required to have on file but not collected, which means that sometimes importers didn’t do the legwork of getting a certificate in the first place.
What is the new rule I need to be aware of as a reseller?
The U.S. government has always asked for items to be safety compliant. Previously, manufacturers and importers were required to have certificates of conformity on file and produce them on request. It’s unlikely that as an individual reseller you obtained one of these in the past.
There is not a new safety standard as part of this rollout, or any new rules regarding safety.
What is changing now is the process by which the government collects safety information. It’s called eFiling, and it requires importers to digitally affirm that they have tested their products for safety, if those products fall under a set of HTS codes regulated by CPSC.
As of now, you need to know the safety standards associated with the products you sell so that you can provide the right documentation if needed.
What is CPSC eFiling and when does it take effect?
CPSC eFiling is a new requirement that changes how certificate of conformity data is submitted when products enter the United States.
Starting July 8, 2026, certificate data must be submitted electronically via the U.S. Customs and Border Protection's Automated Commercial Environment (ACE) system.
If you use a shipping company (e.g. Canada Post, ChitChats, PirateShip) that acts as a broker — as most resellers do — you may be directed to submit the required information via your shipper rather than directly through ACE.
eFiling currently applies only to products that already required a certificate of conformity.
If an item that requires a certificate of conformity does not arrive at the border with one attached or with the proper exclusion cited, your item will be held or stopped at the border. As a result, you could receive a CPSC violation and have your item seized. Initially there may be warnings issued rather than seizures, but it’s unclear when that will change.
Which products require a CPSC Certificate of Conformity?
Any product subject to a mandatory CPSC safety standard, ban or regulation may require a certificate. You can browse products and their associated standards with the CPSC’s Regulatory Robot tool.
The CPSC has not published a final list of all affected products, and guidance is continuing to be updated as the July 8 deadline approaches. However, they have published a sample list of 600 Harmonized Tariff Schedule (HTS) codes associated with eFiling requirements. There may be more of them that come up and the CPSC has stated the list is not all-encompassing.
Categories commonly included are:
• Toys
• Imitation jewellery
• Many clothing and textile product
• Helmets
• Household goods
• Consumer electronics
• Other regulated consumer products
Not every product within these categories will require a certificate — it depends on the specific CPSC rule that applies and the product's HTS classification.
Do vintage and secondhand sellers need to file a CPSC Certificate of Conformity?
Current guidance says that a certificate is not required for used products that were manufactured before the effective date of a CPSC rule, ban or standard, which means they do not need to EFile.
That means you need to check the associated standard with your HTS code and when it was published against the manufacture date of your item. Note this guidance may change as more is continuing to be published.
Even if you are not required to provide a certificate for a vintage item, ideally you will declare an exclusion when shipping to ensure a smooth border clearance.
The same is not true for newer secondhand goods. Items that were manufactured after a relevant CPSC rule, ban or standard came into effect (e.g., the Consumer Product Safety Improvement Act of 2008) and that are now being resold will require a Certificate of Compliance. See the relevant guidance here.
If you sell recently manufactured secondhand goods in regulated categories that fall under the affected HTS codes — such as toys, imitation jewellery or children's clothing — you will be asked to provide a certificate.
What do buyers need to know?
Buyers in the U.S. are not responsible for obtaining or filing a certificate. There is nothing you need to do.
What you do need to know is there may be processing delays on orders as they undergo further inspection at the border, and/or a temporary or indefinite pause from sellers shipping items that are affected by these rules until they have clearer guidance on how to meet the standards. That means you may not have access to as many secondhand items from international sellers on online marketplaces.
I’m an antiques, vintage or secondhand seller. How do I get a Certificate of Conformity?
For most resellers, you will likely apply for the certificate through your shipper at the same time you are supplying your shipping and tariff information. In that case, they would do the eFiling on your behalf. Not all shippers may operate this way so check directly with your shipper.
Note that some shippers (e.g. ChitChats) are temporarily pausing some of their shipping options on affected HTS codes until they have clearer guidance from CPSC and have updated their systems. That means you may not be able to send items that fall under the affected HTS codes under all available postage options until further notice from your shipper.
Only if you move enough volume to have your own ACE account with U.S. Customs and Border Protection would you go through the steps to apply yourself. You can do that here.
Does eFiling/Certificate of Conformity apply to used products?
Under current guidance, it depends on when the used product was originally manufactured. If the item was manufactured before the relevant CPSC rule, ban or standard came into effect, you can apply for an exclusion. Note this may change as information is still being published.
To obtain an exclusion from providing a certificate of conformity, the CPSC notes that sellers may file a “Disclaim” designation (Disclaim A or Disclaim B depending on the product) to indicate that a used product is exempt from certificate requirements. This is voluntary, not mandatory, but will help to avoid delays at customs.
If a used product was manufactured after the relevant CPSC rule, ban or standard came into effect, you do need to get a certificate.
For a list of standards and when they were published, check your product using the CPSC’s Regulations, Mandatory Standards and Bans page and click the corresponding citation or business guidance under “Additional Info,” or use the Regulatory Robot tool or the Business Guidance Library.
Do I need to test the products I sell for CPSC compliance?
If your secondhand product is newer than the Consumer Product Safety Act of 2008, or newer than any other relevant standard that came into effect before its original manufacture, and it falls under one of the regulated HTS codes that requires a certificate, you need to complete eFiling.
That means you would need to test your product if an exclusion doesn’t apply.
We are still trying to confirm if vintage goods manufactured before a relevant CPSC rule, ban or standard was published will continue to be admitted under exclusion rules — assuming they will be excluded, that means you wouldn’t have to test them.
If you apply for an exclusion, not being required to test is not the same as having no responsibility. You cannot sell products that violate the law, for example items that were recalled.
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How do I know when CPSC regulations, bans or standards were published?
For a list of standards and when they were published, check your product using the CPSC’s Regulations, Mandatory Standards and Bans page and click the corresponding citation or business guidance under “Additional Info,” or use the Regulatory Robot tool or the Business Guidance Library.
Can I sell recalled products secondhand?
No. It is illegal to sell any recalled product. This applies to thrift stores, consignment stores, resale platforms, individuals selling at flea markets and yard sales, and anyone else selling consumer products in the United States.
It doesn't matter whether the item is secondhand, whether it was purchased before the recall, or whether you were unaware of the recall. Ignorance of the law is not an exemption. Check CPSC’s list of recalled items.
What about children’s products?
Children’s products carry more obligations for resellers than general-use products do. A few things to know:
Lead and phthalates restrictions: You cannot knowingly sell any children's product or painted furniture that does not comply with CPSC lead limits, which are 100 ppm total lead content in any accessible component part, and 90 ppm in surface coatings. You also cannot knowingly sell children's toys or childcare articles that violate phthalate restrictions.
Furniture manufactured before 1978 is more likely to contain lead paint hazards. The CPSC recommends extra caution with these items.
Specific products that cannot be sold regardless of recall status:
• Drop-side cribs of any age
• Most cribs manufactured before June 2011
• Baby walkers that do not meet current CPSC mandatory standards
• Infant inclined sleep products with a slope greater than 10 degrees (this rules out most of them as the majority are 20 to 30 degrees)
• Mattresses manufactured before 2007 (the CPSC recommends these not be resold)
If you sell children's books and paper goods: Books printed after 1985 are generally okay to sell. Vintage children’s books and collectibles not primarily intended for children are also generally okay to sell but check for recalls regardless.
The CPSC recommends not reselling children's products that don’t have a tracking label permanently affixed. This is a recommendation, not a legal requirement for resellers, but it acts as a signal about a product's history.
I refurbish or upcycle products. Do the same rules apply to me?
If you alter, refinish, refurbish, or upcycle a product, the CPSC classifies you as a manufacturer, not a reseller. Any exemptions based on item age do not apply to you.
As a manufacturer of a children’s product, you are responsible for third-party testing, labelling and certification. For general-use products, you are required to have a “Reasonable Testing Program” in place (see more belong on testing) and issue a General Certificate of Conformity (GCC). If you refinish furniture, you also need a GCC.
There is one category of materials that may be used in upcycled products without requiring additional testing, even for children's products: Uncoated paper and paper products, natural and manufactured textiles, untreated and unfinished wood, and plant- and animal-derived materials (animal glue, beeswax, seeds, shells, feathers, natural leather, and similar).
If your upcycled work stays within these materials, the testing burden is lower. If you are making products intended for children, check with the CPSC's Small Batch Manufacturer Registry, which has provisions for small-volume makers.
Is EFiling required if I send a gift?
Efiling is not required if you send a gift, however it must be non-commercial in nature. Items sold by resellers to individuals in the United States are considered commercial transactions.
Taking action
What are my responsibilities as a reseller under CPSC rules?
We are still waiting to see if there are changes to vintage goods as of the July 8 rule coming into effect. Under current rules, if the item was manufactured before a CPSC standard came into effect, it can be claimed as an exclusion.
Your obligations as a reseller are:
- Check the HTS codes of the items you are sending against the list provided by CPSC.
- Check the date of manufacture of your item and determine if you can cite an exclusion.
- Check with your shipper how to fulfill your Certificate of Compliance if you have a product on the list that was manufactured after its associated standard. This may include testing your item.
- Know the recall status of every item you sell. Check before you list.
- Do not sell products that violate CPSC safety rules. This includes lead content limits, phthalate restrictions and small parts requirements for children's products.
If you learn that an item in your inventory presents a substantial safety hazard after it is sold, you are required to report it to the CPSC.
How do I apply for an exclusion?
If your item was manufactured before a relevant CPSC rule, ban or standard came into effect, you can apply for an exclusion rather than filing a full certificate. The CPSC refers to this as a “Disclaim‘’ designation — Disclaim A or Disclaim B depending on the product — and it tells the border that your item is exempt from certificate requirements.
For most resellers, you would apply for the exclusion through your shipper at the same time you supply your shipping and customs information. Check with your shipper directly on how they are handling this, as processes vary and some shippers are still working out the details.
If you have your own ACE account with U.S. Customs and Border Protection, you can file the exclusion directly through ACE.
Filing an exclusion is voluntary, not mandatory, however it will help to avoid delays at customs and reduce the chance of your shipment being flagged. In addition to this, your item description should clearly state that it's a vintage item/used product and the year it was manufactured.
My used item is newer and I need a certificate of conformity. What do I need to include?
The required information for a General Certificate of Conformity or a Children’s Product Certificate are product identification, the certifying party, the applicable CPSC safety rule, the date and place of manufacture, testing details, any lab information if it’s a children's product, and contact information.
If a testing exemption or exclusion applies to your product, you need to state why testing wasn’t conducted.
For a full list of required information, visit the CPSC’s guidelines for general products and children’s products.
How do I test products?
Unless you are applying for a certificate for children’s products, you can test products yourself. The requirements each product must meet in testing vary between standards, so the best way to figure it out is to read the relevant standard for your product category — for example, art materials and textiles and wearing apparel (clothing). You can find a full list of regulations and standards here.
How do I check if a product has been recalled?
The CPSC maintains a searchable database of all recalls at cpsc.gov/recalls. You can also report an unsafe product at SaferProducts.gov.
The CPSC also has a free mobile app and offers email alerts that you can stay on top of as you’re regularly adding new inventory. Sign up at cpsc.gov/Newsroom/Subscribe.
To learn which CPSC requirements apply to a specific product category, the CPSC's Regulatory Robot tool at business.cpsc.gov/robot can help.
What should I do before shipping products to the U.S.?
A few things worth doing now, before the July 8 deadline:
First, identify what you sell and when it was made. If you ship toys, imitation jewellery, clothing, children's clothing or accessories, helmets, certain electrical goods, or household products to U.S. customers, check whether those products fall under affected HTS classifications using the CPSC’s HTS sample guidance.
Second, check with your shipper. Third-party shipping services are working with U.S. Customs and Border Protection to build compliant processes, and guidance is changing quickly. Some HTS codes are being temporarily restricted while shippers work through the details.
Third, flag any secondhand items for sale that were manufactured after CPSC standards came into effect. If you can’t provide the details needed for a Certificate of Conformity, you may have to stop shipping those items to the U.S.
Fourth, check your recall status. Regardless of eFiling, you are still obligated not to sell recalled products. If you haven’t done a recall check on your inventory recently, now is a good time.
Where can I get more information?
CPSC eFiling FAQ
General Certificate of Conformity FAQ
Rules Requiring a General Certificate of Conformity
CPSC HTS Sample Code List for eFiling
Business Guidance Library
Product Safety Recalls
Report a recalled or unsafe product — SaferProducts.gov
Resale/Thrift Stores FAQ - CPSC
CPSC Resellers Guide — note it has not been updated to reflect changes in 2026 or the EFiling system
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