The need for eFiling depends on whether a product is subject to CPSC regulations.

• Adult apparel is generally not subject to CPSC’s eFiling requirements unless it falls under a specific safety standard or regulation, such as flammability requirements under the Flammable Fabrics Act (FFA).
• Adult accessories (like bags, belts, and jewelry) typically do not require a General Certificate of Conformity (GCC) unless they contain regulated substances (e.g., lead content in metal components).
• Adult footwear may be subject to certain regulations, but most general-use footwear does not require eFiling unless it contains materials that fall under specific safety rules.

For any product that is regulated, a General Certificate of Conformity (GCC) is required, and those products will need to be included in the eFiling process. If your products don’t fall under any CPSC regulations, they won’t require eFiling.

The best approach is to review your product categories against CPSC’s regulated product list and determine if any specific safety standards apply. If you’re unsure, consulting with a compliance expert or checking directly with CPSC can help clarify requirements.

Source: https://www.cpsc.gov/Business--Manufacturing/Testing-Certification

This tool will help you decide whether your product needs certification: 

https://www.cpsc.gov/Business--Manufacturing/Regulatory-Robot/Safer-Products-Start-Here

A determining factor for a product ID change or a revision/version level change depends on the product and the level of risk a company is willing to take. For example, different colors of a product may not require a new ID unless lead testing is involved, as different paint colors require separate test results. However, different specification levels, such as varying components or configurations, generally warrant separate certificates of conformity.

A key guiding principle in making this determination is the concept of "material change." While this doesn’t necessarily refer to raw materials, it implies a substantive change to the product that could affect compliance. 

This remains a gray area, and the industry is working toward refining the criteria for versioning in compliance with CPSC eFiling requirements.

The U.S. Consumer Product Safety Commission (CPSC) provides guidance on what constitutes a "material change" that may necessitate a product ID change or a revision/version level change. According to 16 CFR § 1107.23, a material change includes any alteration in the product's design, manufacturing process, or sourcing of component parts that could affect the product's compliance with applicable safety rules.

CPSC's FAQ on Material Change Testing states that if a material change occurs, the manufacturer must retest the product using a CPSC-accepted laboratory and issue a new Children's Product Certificate (CPC) based on the results. The extent of testing required depends on the nature of the material change.

Sign Up for the CPSC Product Registry & Test It – If using the Reference PGA Message Set, register early and start entering sample data to understand the process before it becomes mandatory.

Centralize Compliance Data – Store test reports, certificates, and supplier data in one system to avoid scattered records. Platforms like Texbase help manage and track compliance efficiently.
Ensure Accuracy & Completeness – Avoid shipment holds by auditing data before submission—check manufacturer details, test results, and product identifiers.

Automate Where Possible – Reduce manual work with bulk uploads or API integrations to the CPSC Product Registry, especially for Reference PGA Message Set users.
Align Compliance & Customs Teams – Set up clear workflows between compliance teams and customs brokers to prevent last-minute delays.

Plan for Long-Term Scalability – eFiling is here to stay, so companies need structured, repeatable processes that can adapt to future regulatory changes.