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CPSC Product Registry CSV upload errors: 14 common mistakes and fixes

Based on CPSC's User Guide for CSV Upload V3 and .CSV Template V3 (both Dec 18, 2025), the Product Registry FAQ V1.4, and CPSC's citation code list. Not legal advice.

The Product Registry lets an importer load many certificates at once from a CSV built on CPSC's Excel template. The format is strict, and several mistakes don't stop the upload. They just produce a wrong certificate that your broker will later reference at entry. You can check a file against every rule below with our free CSV validator; nothing is stored.

Structure errors (the upload fails)

1. Renamed, deleted or reordered columns

The guide says not to rename columns. Required headers must be present or the upload fails. They are Product Update, New Version ID, Primary Product ID, Primary Product ID Type, Certificate Type, Product Name (Model), Manufacturer GLN or Manufacturer Alternate ID, Manufacture Date, Lab 1 Type, Lab 1 Citation Codes, Last Test Date, and Point of Contact (POC) for Test Result Records. Fix: start from the official V3 template, which has 83 columns, and only add columns for extra labs ("Lab 3 Type", "Lab 3 Name"…).

2. Saving as .xlsx or with the wrong encoding

The Registry accepts CSV only. Save from Excel as CSV. If your data contains non-English characters (common when factory names are copied from Chinese documents), replace them with English. Certificates must be in English (16 CFR 1110.9).

3. Leaving CPSC's example rows in

The template ships with sample rows. Delete them, or you will upload certificates for products that don't exist.

Value errors

4. Commas anywhere

CPSC requires removing all commas from values: "Example Company, LLC" becomes "Example Company LLC". Addresses are the usual culprit ("Building 3, No. 88 …").

5. Wrong date formats

Manufacture Date is month and year, MM/CCYY (e.g. 03/2026). Last Test Date and production start/end dates are MM/DD/CCYY. Excel likes to "help" by converting these to its own date type. Format the cells as Text before typing.

6. F963 codes losing their trailing zero

ASTM F963 citation codes are section numbers, and 4.10, 4.30 and 4.40 are distinct codes. If Excel stores 4.10 as a number it becomes 4.1, which is a valid but different code. That error passes upload silently. Fix: Text-format the citation columns and check against the official F963 code list.

7. Wrong separators between codes

Several citation codes go in one cell separated by semicolons, as in the template's own example 1215; 1216. Commas are not allowed (see #4).

8. Invalid enumerations

Product Update must be Y/N. Certificate Type must be GCC/CPC. Lab Type must be ITL (CPSC-accepted third-party lab), LAB (other lab) or NOL (no lab, used for testing exclusions). POC must be Importer, Manufacturer, Laboratory, Broker or Other. Primary Product ID Type must be one of GTIN, UPC, SKU, Model Number, Serial Number, Registered Number or Alternate Identifier.

9. Length limits

New Version ID and Primary Product ID allow up to 19 characters. Product Name allows 250 and description 250. Manufacturer name and address lines allow 100, city 50, zip 10, phone and email 50. Lot Number allows 20. Long Chinese-to-English address translations often exceed the city or address limits.

Logic errors (upload may pass, certificate is wrong)

10. Missing contingent fields

• Product Update = Y requires Current Version ID.
• Manufacturer Is New? = Y requires full manufacturer name, address, phone and email. Later rows can reference the same GLN or Alternate ID alone.
• Lab Type ITL requires the lab's CPSC-ID from CPSC lab search. Lab Type LAB requires an Alternate ID or GLN.
• Lab Is New? = Y requires the lab's name and address. The template's Lab 2 block lacks those columns, so add them ("Lab 2 Name", "Lab 2 Address Line 1"…) when lab 2 is new.
• POC = Other with POC Is New? = Y requires full POC contact data.

11. A CPC with no third-party lab

Children's products must be certified on the basis of testing by a CPSC-accepted lab for rules that require it, so a CPC row normally has at least one ITL lab. Exceptions exist for items CPSC marks as "third party testing not required", such as F963 labeling (section 5).

12. Exclusions entered as citations

A testing exclusion, for example 1500.91(d)(1) for certain untreated materials under the lead content limit, goes in a lab block with Type NOL. You must still cite the underlying rule (1278a) on the certificate (CPSC guidance). See the 1278a page for its exclusions.

13. Reusing Version IDs

A Version ID can be any alphanumeric string but can be used only once per Primary Product ID within a Business Account (FAQ Q9). If two trade partners use the same scheme in different collections, they will hit Version ID errors. Use a scheme such as SKU-YYMM-n.

14. Permissions and the "certify" step

Uploading requires Collection Editor permission or higher. The "Certify valid certificates upon importing?" option only appears for users who can certify. Otherwise, certificates land as "Awaiting Certification" and cannot be referenced at entry until someone certifies them. After certification there is a 48-hour edit grace period, which ends immediately once a Reference PGA Message Set is filed against the certificate.

A 5-minute pre-upload routine

1. Start from the V3 template and delete the example rows.
2. Text-format date and citation columns.
3. Search and replace commas.
4. Run the file through the validator and fix every error.
5. Upload a single row first, check the result in the Registry, then upload the rest.

If you are building rows from scratch, the generator produces a template-exact row plus a matching English certificate PDF from your test report.

Key dates

• July 8, 2026: eFiling mandatory for imported regulated products (formal and informal entries); new certificate content rules (16 CFR 1110.11) apply to domestic and imported products.
• January 8, 2027: products entered for consumption or warehousing from a Foreign Trade Zone.
• January 20, 2027: international mail shipments filed under CBP's new Entry Type 13.
• There is no de minimis exemption for eFiling. Sources: Final Rule (90 FR 1800), CPSC mail guidance (Oct 2026).