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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.
CodeRequirementCPSC note
No Certificate Required
1500.3FHSA LabelingIf the only applicable requirement is labeling under the FHSA, compliance is required but certification is not
1500.14(b)(8)Art MaterialsCompliance is required but certification is not
1500.17Certain bans under 16 CFR § 1500.17Compliance 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
1610Adult Wearing ApparelIf meets requirements for the Commission enforcement discretion (81 FR 12587) and no other rules requiring certification apply
1640Upholstered FurnitureStatutory and regulatory certificate exemption
1750Refrigerator DoorsIf 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).