CPSC eFiling Brand Compliance Guide

Official CPSC guidance

We strongly encourage all brands to read and understand the official CPSC guidance before reviewing the summary below. These are the authoritative sources and should be your first point of reference:

• Does eFiling apply to me?

• CPSC Regulatory Robot — a free tool that asks a few questions about your product and lists the safety rules that may apply (a starting point only; it is not a compliance determination)

• eFiling — overview and resources

• Rules requiring a General Certificate of Conformity

What is changing?

From 8 July 2026, where a product requires a US Certificate of Compliance, that certificate information must be submitted electronically to US Customs at the point of import ("eFiling"). This does not introduce new safety standards — it changes how existing certificates are submitted. If a product already required a certificate, that information now needs to be filed electronically. If a product did not require a certificate, eFiling does not apply.

What is in scope?

The requirement applies only to products that fall under a CPSC safety rule. Wolf & Badger prohibits the sale of most products that require a certificate, including children's items and electronics, so for most brands the impact is limited to adult apparel.Adult apparel is covered by US flammability rules (16 CFR Part 1610). Most everyday garments are exempt from testing, and CPSC does not enforce certification for adult apparel made from these exempt fabrics.

Most likely exempt — no certificate needed — if made entirely of:

• any fabric — any weight, smooth or textured — made wholly of polyester, nylon, acrylic, modacrylic, olefin (polypropylene/polyethylene), or wool; or

• a smooth-surface fabric of any fibre weighing 2.6 oz/yd² (about 88 gsm) or more — which covers most normal-weight cotton, linen, denim and similar.

May not be exempt — may need a certificate — if it is:

• a lightweight, sheer or fine smooth fabric under 2.6 oz/yd² that is not one of the fibres above — for example sheer silk, fine cotton lawn, lightweight viscose/rayon; or

• a raised or textured surface (e.g. velvet, chenille, fleece, brushed fabrics) that is not made wholly of the fibres above — for example cotton velvet or viscose chenille.

Jewellery, bags, accessories and most other categories sold on Wolf & Badger are generally outside CPSC certification.

If in doubt, run your product through the CPSC Regulatory Robot.

What we need from you

1. On your listings — always

Please make sure the following is accurate on every adult apparel listing, as it will determine whether your product is exempt:

• Fibre composition (e.g. "100% polyester," "70% viscose / 30% cotton")

• Surface type — smooth or raised/textured

• Fabric weight (gsm or oz/yd²)

2. If you have registered with CPSC, we may require that you provide us with the following on request:

• Certifier ID

• Product ID

• Version ID

3. A General Certificate of Conformity (GCC) — where required

For items that are not exempt, we may request a General Certificate of Conformity. This is the certificate confirming the product meets 16 CFR Part 1610, and it must be supported by flammability testing (a test report or a signed guaranty — third-party lab testing is not required, so testing from your mill or supplier is acceptable, and one test can usually cover a whole fabric across multiple styles).

A GCC sets out:

• the product(s) it covers;

• the safety rule it is certified against (16 CFR Part 1610 – Wearing apparel);

• the importer/manufacturer certifying compliance;

• a contact who holds the test records;

• the date and place of manufacture;

• the date(s) and place(s) of testing; and

• the testing laboratory (if a third-party lab was used).