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CPSC requirements that need no certificate (and when to file a Disclaim)
CPSC's code list includes entries where compliance is required but a certificate is not. If no certificate is required for a product that falls under a CPSC-flagged HTS code, the filer may send a Disclaim message instead of certificate data (CPSC guidance, Sept 28, 2026):
- Disclaim A ("product is not regulated by this agency"): the product is captured by CPSC's HTS codes and within CPSC's jurisdiction, but no rule requiring a certificate applies (CPSC's examples: adult hats and gloves, collectible toys intended for adults, sport helmets other than bicycle helmets). An intended use code such as 100.XXX, 130.XXX (except 130.001-005) or 980.000 is required.
- Disclaim B ("data is not required per agency guidance"): a rule applies but CPSC exercises enforcement discretion, for example adult wearing apparel claiming 16 CFR 1610.1(d)(1) or (d)(2). Intended use code 130.006 is required.
| Code | Requirement | CPSC note |
|---|---|---|
No Certificate Required | ||
1500.3 | FHSA Labeling | If the only applicable requirement is labeling under the FHSA, compliance is required but certification is not |
1500.14(b)(8) | Art Materials | Compliance is required but certification is not |
1500.17 | Certain bans under 16 CFR § 1500.17 | Compliance is required but certification is not unless the Commission voted to include the ban in the list of certificate requirements above; see 78 FR 28080 |
1610 | Adult Wearing Apparel | If meets requirements for the Commission enforcement discretion (81 FR 12587) and no other rules requiring certification apply |
1640 | Upholstered Furniture | Statutory and regulatory certificate exemption |
1750 | Refrigerator Doors | If meets requirements for the Commission enforcement discretion (84 FR 37767) and no other rules requiring certification apply |
If a certificate is required for another rule, use testing exclusion codes on that certificate instead of a Disclaim.
CPSC's HTS list states that filing a voluntary disclaim "may benefit an importer's risk score" (HTS list, Oct 2026).