Worked sample — illustrative

What a certificate review actually looks like

Nobody buys a review they cannot picture. This is the shape of the audit, worked through on one example product. It is a sample, not a client engagement — real reviews are confidential, and the factory, laboratory and dates below are illustrative.

1 · Rule determination

Before anything else: which certificate, and under which rules? A toy for children under three lands as a CPC (children's product certificate), with the applicable rules drawn from the CPSC lists rather than a general claim of compliance.

16 CFR part 1250 — toy safety (ASTM F963 as incorporated)
16 CFR part 1303 — lead in paint and surface coatings
16 CFR part 1307 — phthalates in children's toys
16 CFR part 1501 — small parts, applicable under age three
15 U.S.C. § 2063(a)(5) — permanent tracking label

2 · The seven eFiling data elements

These are the elements that transmit electronically at entry. The review fills each one and shows you where the evidence for it comes from.

1 · Product identification

Wooden stacking rings, SKU WS-104; 6–18 months; children's product — toy

Name, identifier and description match the invoice, packing list and label.

2 · Rule citations

16 CFR part 1250; 16 CFR part 1303; 16 CFR part 1307; 16 CFR part 1501

Only the rules that actually apply to this product, not a blanket compliance sentence.

3 · Manufacture date

2026-07-18 (batch WS-104-B2)

Ties to the units in this shipment, not a generic year.

4 · Manufacturer / private labeler

[Factory] — full name, address, contact

The entity that certifies. For a private-label import, the importer is named as the responsible party.

5 · Testing date

2026-06-30

Testing that covers the production units being imported.

6 · Testing laboratory

[CPSC-accepted lab] — name, address, acceptance scope

Acceptance for these specific tests, stated rather than assumed.

7 · Point of contact

Importer of record — compliance contact

Who CBP or CPSC contacts if a message set is questioned.

3 · Findings

This is the part you are paying for: what is wrong, why it matters at the border, and exactly what to change.

Finding 1 — the certificate cites no rule

The supplier's one-page document says the product is "compliant with CPSIA and ASTM standards" and gives no rule citations. That is not a certificate of compliance: 16 CFR 1110 requires the specific applicable rules to be listed, and a citation-free document also cannot be transmitted as eFiling data at entry.

Fix: Rule citations replaced with the specific parts: 16 CFR part 1250 (ASTM F963 toy safety), 16 CFR part 1303 (lead in paint), 16 CFR part 1307 (phthalates), 16 CFR part 1501 (small parts, applicable under age three).

Finding 2 — the test report covers the wrong units

The attached laboratory report tested one natural-finish sample in the previous production year. The shipment includes three colourway SKUs, and paint colour is one of the variables that affects the lead-in-paint and phthalate results. On paper the certificate asserts testing that does not cover what is on the bill of lading.

Fix: A periodic testing plan added under 16 CFR part 1107 covering colourway and material changes, so re-testing obligations are defined instead of assumed.

4 · The broker briefing sheet

One page your freight forwarder or customs broker can act on, so the data handoff for the Full PGA Message Set does not become a week of email. It carries the importer of record, the certificate type, each of the seven elements in the shape ACE expects, the point of contact for an RFI, and the documents on file behind every value.

5 · Entry risk notes

The three values most likely to be questioned at entry, and the evidence that answers each
What to re-test when the colourway, material or factory changes (16 CFR part 1107)
Which documents must be retrievable for the retention period if CBP or CPSC asks
What to do in the first 24 hours if a message set is flagged

Not sure you need it yet? Score your readiness free — eight questions, out of 100 — or check which certificate your product needs.

This sample is illustrative and is not legal advice or a compliance determination for any real product. EntryReady is a documentation workspace and compliance-review service, not a law firm, customs broker or testing laboratory. Rule references above come from the CPSC rule lists transcribed into EntryReady's rule database; confirm the current edition of each standard for your product. Not affiliated with the U.S. CPSC or CBP. EntryReady is operated in Australia.