CPSC Announces Results of Data Submission Study, to Consider Next Steps for ACE Filing Pilot
The Consumer Product Safety Commission will hold a public meeting this fall to discuss next steps for its pilot of electronic filing in ACE, said Sabrina Keller, deputy director of CPSC’s Office of Import Surveillance, at the National Customs Brokers & Forwarders Association of America Government Affairs Conference Sept. 24 in Washington. The commission recently published the results of a study of data elements found on CPSC certificates of compliance and their relevance to targeting, she said.
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That study found that the ability of a company to provide certificates at the time of entry or soon after is “strongly associated” with product compliance. Of the importers studied -- CPSC did not look at volunteer participants, but rather a sample across ports -- those that never provided a certificate were five times more likely to have a violation than those that provided a certificate within 24 hours, while those that provided a certificate more than 24 hours after one was requested were three times more likely to have a violation, Keller said.
“Staff concludes that if a means to verify the presence of a valid certificate is incorporated into the [Risk Assessment Methodology targeting] score before import, that information would be a major predictor of a violation,” the study said. CPSC also looked at the relevance of individual data elements, and while it did see trends, the data was not complete enough to be considered predictive, Keller said.
The study had been recommended in 2017 after CPSC wrapped up its eight-participant e-filing “alpha” pilot. That pilot was a “success,” with particular benefits to companies that uploaded their certificates to a ”registry” and tied them to a unique identifier transmitted with entry documentation (see 1701270043). In its recommendations, CPSC staff had also recommended that the commission proceed with a “beta” pilot with up to 100 companies allowed to participate.
Given the option by CPSC staff to either conduct its study simultaneously or separately from the beta pilot, the commission chose to run the study beforehand. In its recommendations, CPSC staff noted the danger of losing “momentum” from the alpha pilot if the study were conducted separately. “CPSC has made great progress in working with importers on eFiling the PGA Message Set data over the last 2 years,” it said. “The CPSC team also built much of the IT infrastructure, including the Product Registry, to support the collection of PGA Message Set data by CPSC. Doing the study ahead of, rather than in conjunction with, the Beta Pilot, risks losing the eFiling momentum gained during the Alpha.”