One month after the Consumer Product Safety Commission (CPSC) certificate eFiling launch, the feedback the RAC has received is mostly positive, Overall, the implementation is proceeding fairly smoothly. Pain points still exist, but major upheaval did not occur. Following are some of the issues that still need to be addressed:

• CPSC is slow to respond to tickets.

• Unexplained rejects are still occurring: Some brokers are still seeing PGA rejects with the same block of text and no error code. These later receive “may proceeds” and CPSC has said brokers can ignore the reject. But, for brokers, ignoring rejects sets a dangerous precedent.

• Some Reference message sets are rejected with the “The Referenced Product was not found” error. CPSC attributes this to importer or broker errors in the data. However, some brokers have gone back to clients to verify that the information they are entering does match in the Registry. Although the entry will receive a May Proceed, this raises the question of just how effectively the Registry is speaking to ACE.

• Confusion over highly flammable adult wearing apparel, such as silk scarves, which some importers believe are exempt, but CPSC says a Certificate is required. Brokers are put in a bad position when importer clients insist that they do not need a certificate.