CPSC eFiling and the De Minimis Shutdown: Every Low-Value Shipment Now Clears Customs

Michelle Corrigan Erikson, Partner | Stinson LLP

Michelle Corrigan Erikson is a partner in Stinson LLP’s St. Louis office whose practice sits at the intersection of products liability defense and consumer product regulation. Across nearly three decades she has defended manufacturers and distributors in personal injury and property damage claims involving consumer, industrial, and food products, with a concentration in children’s products. She also counsels clients on the regulatory side of the same exposure — warning programs, risk management strategy, supply chain agreements, product recalls, California Proposition 65 compliance, PFAS regulation, and the coordination of FDA and CPSC obligations — so that the compliance file and the litigation defense are built to hold together.

• Education & Credentials

Michelle earned her J.D. from Loyola University in 1997 and her B.S. in Management and Marketing, cum laude, from Canisius College in 1994. She was admitted to practice in Louisiana in 1997 and in Missouri in 2005. She is also admitted before the U.S. District Court for the Eastern District of Louisiana (1997), the Eastern District of Missouri (2005), the Western District of Missouri (2011), and the Southern District of Illinois (2015).

• Recognition & Leadership

Michelle has been recognized in The Best Lawyers in America© list from 2023 through 2027. Her trial work was honored by Missouri Lawyers Media in the 2023 Missouri Lawyers Awards for Verdicts and Settlement Winners, which recognizes the best defense wins at trial in Missouri that year. She has also published extensively for the practitioner audience on consumer product compliance, including “Consumer Product Recalls on the Rise: Important Compliance Reminders for Consumer Products Manufacturers and Sellers” and a series of guides to current and proposed regulation of bassinets, play yards, bedside sleepers, and flame retardants.

• Professional Involvement

Michelle is a member of the Juvenile Products Manufacturers Association and serves on ASTM International’s Committee on Consumer Products (F15) and its Committee on Sports Equipment, Playing Surfaces, and Facilities (F08), including the juvenile products subcommittees, where consumer product standards are actually written. She is active in the Defense Research Institute, including its Children’s Products and Women in the Law subcommittees, and belongs to The Missouri Bar, the Bar Association of St. Louis, and the Louisiana Bar Association. She speaks regularly on product safety and compliance topics, including PFAS reporting requirements, product bans, and litigation trends, and California Proposition 65 compliance in supply chain agreements.

• Experience

Michelle has served as national counsel for a chemical manufacturer, defending hundreds of product defect claims nationwide over more than fifteen years. She obtained a complete defense verdict for a medical device manufacturer in a wrongful death jury trial, and led the litigation team that secured a complete defense verdict for a body armor manufacturer at an April 2022 jury trial in St. Louis. She has represented clients in FDA food recalls involving bacterial contamination and foreign material, and in CPSC recalls involving small parts and fire hazards, and defends PFAS litigation matters. Her earlier construction defect practice produced reported decisions interpreting Louisiana’s New Home Warranty Act, including Stokes v. Oster, 807 So.2d 987 (La. App. 5th Cir. 1/15/2002) and Liberty Mut. Fire Ins. Co. v. Ravannack, 2004 WL 612962 (E.D. La. 3/24/2004).

Elsa Manzanares, Partner | Stinson LLP

Elsa Manzanares is a partner in Stinson LLP’s Dallas office who works to minimize trade and corruption risk in international transactions. A former in-house counsel, she advises on the U.S. and international rules governing imports and exports of goods, services, software, and technology for technology companies, defense contractors, manufacturers, and retailers, and for clients in the aerospace, explosives, electronics, semiconductor, firearms, chemical, military training, consumer products, energy, and financial services sectors. Her import practice — U.S. Customs and Border Protection regulations, antidumping and countervailing duty matters, and tariff exclusions — is the customs side of the same entry that now carries a CPSC certificate.

• Education & Credentials

Elsa earned her J.D. from the University of Texas School of Law, her M.P.P. from the Harvard Kennedy School, and her B.A. in Economics and History from Yale University. She clerked for Justice Ann C. McClure of the Court of Appeals for the Eighth District of Texas in El Paso and for U.S. District Judge David Briones in the El Paso Division of the Western District of Texas. She is admitted in Texas and before the U.S. Court of International Trade.

• Recognition & Leadership

Elsa has been selected to The Best Lawyers in America® list from 2024 through 2026. She received the Hispanic National Bar Association Regional President of the Year Award in 2022, was named a 2020 Top Latino Lawyer by Latino Leaders, and was included in Lawyers of Color, Nation’s Best 2019. Earlier recognitions include the Greater Dallas Hispanic Chamber of Commerce La Cima Latina Entrepreneur Award and the Dallas Bar Association Outstanding Minority Attorney Award, both in 2018, the Texas Diversity Council’s Dallas Top 50 Women Lawyers in 2018, and Super Lawyers Rising Star in 2009 and 2011–2012. The Office of the U.S. Trade Representative appointed her to serve as a panelist reviewing antidumping and countervailing duty disputes under NAFTA Chapter 19.

• Professional Involvement

Elsa is a former board member of the Law360 International Trade Editorial Advisory Board and belongs to the American Association of Exporters and Importers, the International Compliance Professionals Association, and the Society for International Affairs. She has served as President, President-Elect, Vice President, and board member of the Dallas Hispanic Bar Association, on the Dallas Bar Association’s board of directors and as chair of its Minority Participation Committee, and as Region XII President and founder and chair of the Compliance & Ethics Section of the Hispanic National Bar Association. She writes and speaks frequently on trade, most recently on international trade and tariffs updates, tariff impacts in M&A, and current events in international trade.

• Experience

Elsa has represented U.S. and foreign companies in Department of Commerce and State Department investigations under the Export Administration Regulations and the International Traffic in Arms Regulations, and appears before the Treasury Department’s Office of Foreign Assets Control on sanctions matters. She counsels clients through Committee on Foreign Investment in the United States reviews, including voluntary notice procedures, and builds Foreign Corrupt Practices Act compliance and third-party vetting programs. Her day-to-day work includes export licensing of defense articles under ITAR and dual-use goods under the EAR, anti-boycott compliance, sanctions and embargoes, CBP import regulations, trade compliance program development, pre- and post-M&A due diligence, tariff exclusion filings, Foreign Trade Regulations compliance, and drafting international trade contracts.

Boaz Green, Partner | Neal Cohen Law LLC

Boaz Green is a seasoned consumer product lawyer who provides practical advice tailored to a company’s business and culture, informed by a deep understanding of consumer product safety laws and regulations and the internal workings of the Consumer Product Safety Commission (CPSC). A Partner at Neal Cohen Law, Boaz has extensive experience advising and representing companies on product safety compliance, policy, and enforcement, as well as on broader consumer product regulatory requirements such as labeling, advertising, and marketing under federal and state law. He works with a diverse range of clients—from leading retailers, private labelers, and manufacturers to innovative startups, platform sellers, and franchisers.

• Education & Credentials

Boaz earned his J.D. cum laude from Georgetown University Law Center and his undergraduate degree summa cum laude from New York University’s Gallatin School of Individualized Studies. He was admitted to practice in New York in 2006 and the District of Columbia in 2008.

• Recognition & Leadership

Boaz is recognized as a leader in product safety law. He has organized and moderated several Practising Law Institute (PLI) Continuing Legal Education sessions and has been invited to teach in the Consumer
Product Safety Professional Certification Program of the Society of Product Safety Professionals. His government service as Senior Counsel and later Chief Counsel to a CPSC Commissioner underscores his standing as an authority on the agency’s operations and enforcement priorities.

• Professional Involvement

Boaz is a regular contributor and speaker at the International Consumer Product Health and Safety Organization (ICPHSO) conferences, the Practising Law Institute, the Society for Product Safety Professionals, and industry trade shows and events. Through these engagements and his teaching, he plays an active role in educating the product safety community and shaping best practices in the field.

• Experience

From 2014 to 2018, Boaz served as Senior Counsel and then Chief Counsel to CPSC Commissioner Marietta Robinson, where he forged strong ties with CPSC leadership, management, and staff and worked closely with stakeholders across Congress, business, and the non-profit sector. Before joining Neal Cohen Law, he was Counsel at Keller and Heckman, a well-known regulatory firm, focusing on complex consumer product regulatory and enforcement matters, and earlier practiced as a litigator at a major international law firm and as a Trial Attorney at the Commodity Futures Trading Commission. Today, his practice centers on guiding clients through CPSC reporting, recalls, enforcement actions, investigations, and import surveillance—advising on responses to Notices of Violation and product safety issues and negotiating recalls, and earning the trust of Fortune 500 companies to assess regulatory compliance, conduct investigations, and negotiate product recalls.

SESSION 1 – CPSC eFiling Rule: Important Compliance Requirements for Importers of Consumer Products | 12:00pm – 1:00pm ET

The CPSC now requires mandatory electronic filing of Certificates of Compliance for imported consumer products subject to certain safety standards and regulations, and the rule reaches every finished product that requires certification, including de minimis shipments. This session covers which products need a Children’s Product Certificate — generally supported by testing at an independent third-party laboratory accredited by the CPSC — and which general use products need a General Certificate of Conformity, which may be tested internally or by a third-party lab. It identifies who carries the obligation: importers are primarily responsible for e-filing certificate data, while manufacturers and private labelers must issue certificates for domestically produced products, or where an overseas manufacturer provides none. It then walks through the certificate data elements transmitted through the Automated Commercial Environment, the choice between filing in the CPSC Product Registry at cpsc.gov and submitting directly in ACE for each product, the July 8, 2026 deadline for General Import Entries and the January 8, 2027 deadline for Foreign Trade Zone entries, and the penalties, fines, seizures, and holds that follow a failure to file as CBP implementation advances.

BREAK | 1:00pm – 1:10pm ET

SESSION 2 – After the Parcel Clears: CPSC Enforcement, Certificate Integrity, and Recall Exposure in the Post–De Minimis Marketplace | 1:10pm – 2:10pm ET

Transmitting a certificate at entry is the easy part — what follows is where the real liability lives. With de minimis gone and every low-value shipment now entering the formal stream, CPSC has an unprecedented data trail into millions of small-parcel imports, and it is using it: counterfeit safety-label investigations, third-party testing integrity reviews, eSafe takedown notices past the 100,000 mark, eight-figure late-reporting penalties, and criminal referrals. This session picks up the moment the data hits ACE and walks counsel through the enforcement machinery on the other side — port detentions and refusals, certificate and test-report challenges, Section 15(b) reporting triggers, marketplace and dropshipper liability as “distributors,” and how to build a compliance file that survives scrutiny. Led by a former Chief Counsel to a CPSC Commissioner, the session gives practitioners a realistic view of how the agency actually evaluates, escalates, and resolves these matters.