California Textile EPR Law Registration & CPSC eFiling Update

Important Compliance Updates for TGA Members

Quick reminders about two recent and upcoming deadlines:

California Textile EPR Law – July 1 Registration Deadline

Under California's Textile Extended Producer Responsibility (EPR) law (SB 707), producers of covered textile articles, including many travel goods products, were legally required to register with the designated Producer Responsibility Organization (PRO), Landbell USA, by July 1, 2026.

Please note the American Apparel & Footwear Association (AAFA) has filed a court case challenging California’s decision to award the PRO to an organization called Landbell, which is owned by a for-profit company. An injunction hearing is set for August 7.

TGA members should discuss with their legal counsel to determine whether they meet the definition of a producer, confirm any applicable registration requirements, and evaluate next steps if they have not yet registered.

CPSC eFiling Due July 8

The mandatory compliance date for the Consumer Product Safety Commission’s (CPSC) eFiling requirement is July 8, 2026.

eFiling is the requirement for importers of regulated consumer products (including travel goods) to electronically file data elements from Certificates of Compliance (CoC) with the U.S. Customs and Border Protection (CBP) via a Partner Government Agency (PGA) Message Set. While customs brokers will typically transmit the data, the importer of record is legally responsible for the accuracy and completeness of filing.

eFiling does not change which products require CoCs or create any new testing requirements – it requires that importers file that information for each shipment, moving beyond the old ‘upon request’ system of compliance.

There are also no de minimis exemptions for eFiling – eFiling applies to any product subject to a CPSC rule requiring a certificate.

Where can I find more resources?

• eFiling Document Library
• eFiling Quick Start Guide (January 2025)
• eFiling FAQs
• eFiling Product Registry User Guide (September 2025)

CPSC also hosted a series of webinars to prepare for implementation of the new eFiling system. Recordings are posted on CPSC’s YouTube channel.