 So, welcome to the session for the beta pilots. I hope some of the opportunity to read on our web page about the filing or have heard me presents before. The purpose of this session is to provide. That second overview to the filing and the beta pilot and to go through some of the benefits of participating as well as allow opportunity for you, the audience to ask questions and hopefully by the end, we will convince you to participate with us. I'm going to forward so 1st, welcome again. This is the 1st of 2 point questions they'll have for this session. Simply this question, please provide your name and the company you are representing. This is for our purposes to see who's in attendance today. This will not be shared with others. So, Justin, go ahead. What was that? Yeah, so I'll give it a few moments or all of you to respond to that. Today's agenda and I'll provide an overview of the filing. Discuss the certificate data elements and then the PGA message set option. Then I'll go into industry benefits. There's a total of 6 and then the role of importer and how you as an importer can get involved. Then I'll address some of the most recent development and some of the components of the product registry. As you can see in the sample list, and then I'll open it to discussion and for any of your questions. So, what is e filing? It is our newest initiative at CPC that modernizes how certificate data is processed. By enabling importers of regular consumer products like you to electronically file certain data elements for my search, big compliance via the partner government agency message set. So, this many of you already familiar with the entry process. This is like an indendum and we are requesting specific certificate data that is already found on the certificate and as an importer of a regulated consumer product. Including children's products and other general use products you already required. Since 2008 to have certificate and. Dr testing on your product. This is simply transitioning from paper or PDF to an electronic. So, why are we doing this from CPC perspective? We only. We are unable to use the certificate data as currently as it currently stands for our risk assessment and targeting. We only really review the certificates once we identify. So, I lost this. Have to reshare my PowerPoint all right. So, let me start over about why we're doing e filing. As I said. We only review this once we identify shipment for an exam place that should be on hold. And that at that point, our investigators at the board. We'll examine the documents and request the certificate and because the data for the certificate comes in usually as a PDF or a format. We do not have the opportunity for risk assessment and targeting because. That information is not any format that we can use for our risk assessment methodology. So, by asking importers to. File the certificate data electronically it provides us more substance to use in our risk assessments. Have previously done studies and we have found certain elements on the certificate as well as the lack of certificate. At the time of import does result in higher risk. So, we want to incorporate those data points into. I risk assessment to be able to more actively to target shipments of standard hazards. I'll later go on into the benefits of why you should participate in the filing. On the right, you see the timeline we currently are. In between fall 2022 and spring 2023, we are currently doing development with importer input. We do have a select working group of 9 importers who are participating with us. I will address that on a later slide. Relatively soon we'll finalize the tear and that will be made available for brokers and software developers to begin their development including. Starting this summer 2023 will conduct training and. Some early testing in the fall 2023, we will begin the beta pilot, which will run for 6 months. And then by year and 2024, we hope to finalize or will make me so this. So, this is to say that we plan to make a permanent. So, filers or importers of regulations and products will be required to provide the certificate elements. At the time of import during the time of the beta pilot as a volunteer. Won't necessarily have to provide the certificate data for every product you bring in, but we will encourage you to build up to that capacity. Given that we are choosing and make this a requirement. This by participating that's 1 of the benefits is that you have more time. To transition to that electronic filing, if you wait towards the end of 2024. Until the road making is finalized or be shorter. A phase in period and there. And you would have a steeper learning curve at that moment. So, if you participate with us now, that's my 1st kind of that I'm offering. Is that you have much more time to transition and if you run into any. You would be able to work with us to resolve that. The way till 1 rule making is finalized. We will begin flagging more and submitting same mornings to importers who fail to provide complete. Certificate data and that may result in a higher risk score. Or your shipment so even advantageous participate now, because some more data you provide in advance. To lower risk score. So, these are the certificate data elements that we are. Testing filing and it's very similar to. Data that you already find on certificates, I'll go through this briefly. First is the ID of the finished product. The 2nd is each consumer product safety rule to which the finished product has been certified. 3rd is a date when the product was manufactured. 4th is place of manufacturing where the finished product was produced, manufactured, produced, or assembled. 5th is the date of. Lab testing 6 is the part and testing certificate depends, which is the laboratory. And last is a check box indicating that a report certificate currently exists for the finished product. And as part of the filing, we'll have 2 options. I will. The 1st option, probably the preferred option is to use our product registry, which is a database that we are creating and will maintain. This is solely on CPSC's and so the importer will file the certificate data and the registry and then. Reference a product registry ID with their entry documents, which would be submitted in 8th and then all that data will be sent to the risk system methodology that CPSC operates. By doing it this way, if you consistently bring the same product over and over again, you only have to file the certificate data once. And then only reference that certificate while submitting it into a, so we're talking about. Only a couple of lines of data in the, of pg line data in the message that the 2nd option is to file all the certificate data at the time of entry. Which, as I mentioned, is 7 data points, but that data elements, but that would include. On many more data points because there is some like self data points per each element. Every single time for each and via ace. So, if you do bring a repeated product, you will just have to recent, recent the data. Right, so these are the benefits that we are offering as a participant in the filing in the data pilot. Specific 1st, we'll be testing a shorter review clock. So the data pilot participants will. Benefit be shorter to a message and I believe many of you already receive. 1 us notification from CPSC where you shouldn't be under review the maximum of time as it currently stands is. 16 business hours in the environment or 8 business hours in an air and truck environment. From the time that entry is filed and that is if you file on or excuse me. The time of actual arrival of entries filed on the 3 business days, there are ways to make it shorter. However, this. You shorter review clock could be advantageous. Because it wouldn't we are not at this point when we when we test this, we will be looking at 1 at what point you. File the entry documents, whether it's more or less than 3 days. We would just have a blanket review clock where it is. 8 business hours after entries filed in the ocean environment or 4 business hours in the air and truck environment. So this means if you file well in advance. The review period will end well in advance of your shipping rival. If you. Are delayed and you provide the entry documents right before arrival. The clock will begin at the time of the entry. After at the time entry is filed, not the date of actual arrival. So, at that point, the clock will still process. In 48 business hours and won't be delayed depending on when by the entry documents. Secondly, we would data participant basically reduction in their risk score over time. And that's based on the amount of data provided as well as. Providing by and data so that's an advantage of participating earlier with us because. The data you provide during the data pilot will be incorporated into your scores. By waiting until the final rule that just means less months of data that could have been provided. The reduction in risk scores may result in reduced whole times and fewer exams, which may reduce cost to the importer. Third, we promise that there will be no disruption to operations during the pilot. We will continue our normal business operations at the port, but there will be no extra scrutiny or holds during the pilot. We won't be holding your shipments to check for the certificate specifically if you participate in the pilot. Instead, we'll probably do some post-audits after the pilot begins and if your shipment is held and an exam is requested and this is again, based on normal operations that our investigators are conducting, conducting as of today. Those holds and exams would be prioritized. For this, the beta pilot will increase our focus on higher shipments and which may result in fewer holds to check for certificates that we'll have a greater focus in higher risk products. We'll hold to be more likely to perform for substantial violations rather than for certificates as the certificate data would provide at the time of entry, but we would have time to review the data before making that decision. So again, fewer holds may result in reduced cost to the importer. As a participant in the beta pilot, CPSC staff would be readily available to answer any of your product regulatory questions. These are in addition to questions related to filing, these are specifically related to certain regulations to your products that you are importing. And lastly, you have the opportunity to provide feedback, which would be more rulemaking before the full implementation of filing. So, for the role of the importer for the success of filing, we really need your support and participation. Ultimately, the importer, you are the main participant in the beta pilot because you have the oversight of the data. And you would be responsible for filing with the assistance of your broker. So, as an importer, first, we need to identify a broker partner. If you work with most brokers, we encourage asking all of them, but you can just work with 1. This only applies, of course, if you're not a self-filer and then you would continue to work with your broker partner and identify CPSC regulated products that will be included in the beta pilot. Again, these are all products regulated by CPSC that require a certificate. If you go to our web page, you will be able to find that information. And prior to the pilot, we will disseminate a list of HTS codes that we would be flagging as part of the pilots to assist you to find those regulated products. Again, if you want to start with a subset of products that you have certificate data readily available and then build up to your whole portfolio, that would be possible as well, but we do encourage that you work as hard as possible to get to that point where you're providing certificate data for all of your regulated products. And lastly, you would be responsible to manage certificate data in an electronic format that can be transmitted in the full message set or the product registry broker's report. The product registry will be built in such a way that allows for data to be uploaded in a batch or via an UPI as well. As certificates being submitted in your face, and I'll touch on that later. So, again, if you were willing to participate, please notify us, reach out to us or email the final slide. Again, identify broker applicable and. Step 3 is to complete the beta pilot onboarding and system training, which will begin this summer. Or it's to be applicable if you choose user product registries to enter the certificate data. It will be the file, the pg message set, and then 6 steps to provide us with periodic feedback throughout the beta pilot. We will use surveys during the beta pilot to get your feedback. But of course, we'll be open to any of your feedback via email or phone call. I do want to address if you are a broker on this call. You do have to find an importer to participate with because the importer is the 1 who is responsible for the data itself. The broker is not responsible for the certificate data, so you do have to have a partner. So, obviously these steps are different, but please reach out to clients who would be interested in the beta pilot. Imported regulated consumer products. And if you have other questions, please ask. This is James just just to educate me a little bit. I'm I'm I'm the deputy at exit within exit. So, so help me understand. So, right now, in terms of. Your importers that have volunteer for the beta project is there a cap. That you're looking for and how many do you have right now that are participating? Our goal is to find 30 to 50 importers. We're reaching that goal. We are. Approximately 22, so we still have money available for importers. Okay, that sounds good and I guess my 2nd question is. So, by the end of I guess, it's the May timeframe that you're targeting with is it PGA messaging? Can you can you talk a little bit around that? Is that is that a collaboration mechanism with CVP? Yes, we're working very closely with CVP to build the message that. I've already had most meetings with them and it'll be shortly beginning. Development cycle, and then that should conclude by the early summer at that point, we'll begin testing with actually the working group of 9 purchase 9 importers that you see on this slide. So, let me continue on and James, if any other questions, please pull them to the end. That sounds good. Thank you. Yeah, so. As I mentioned previously, we have a working group of 9 importers who are actually who we are actually consulting with as part of the development. And they're being supported by their broker and industry partners. So, they are excuse me, I'm hosting bi-weekly with that bi-weekly meetings with them and they're providing iterate feedback and development of product registry. Including addressing the system requirements functionality process flows and data elements cover a few of those process flows on the later slides. They would be the first to test integration of the registry to their internal systems, which will serve as a blueprint for the remaining participants. So these bi-weekly meetings are posted on CPSC's calendar and are open to the public as well for you to listen in. So, this working group, we have covered many topics that was highlighted in 3. So, we already covered a majority of them. Initially, we covered business account creation and management, which includes adding additional administrators and creating and managing collections. We are using the term collection as essentially the sub registry. This is where you will have the collection is where you would store the certificates and we'll provide the option where you have multiple collections in your account. Additionally, we have already addressed how you would add and edit products to your collections, manage products, bulk, import, export and editing. We also have discussed the user permissions and management, creating and managing user accounts, for example, especially for third parties. So, as an importer, you would be the business account holder. Because you are the one, this is your data that you need to manage. However, you can provide permissions to other third parties, like your brokers or labs, to have access to your collections. And they will be able to provide data for you. Of course, at the end, you would still be responsible to certify. That's where the creation management user accounts and the managing collection users will come in. And that is, and that's related to why we would be able to create multiple collections, be able to organize elections based on what third parties are assisting me in providing data. So, this first screenshot is essentially how your account would look, your business account would look in the product registry of the company information at the top. This second box, where is this company account admin? That is for the business account holders and those should solely be the importers. So, the company, for example, here is called storm importers. So, you can add multiple account admins and then just the roles. As you see fit, but again, these are just of the importer later show how you the flow where you get at third party users to your flow. And at the bottom, that's where your collections will be listed. And if you were to select this purple bottom, purple button in the bottom, right? That's when you can add a collection where you can add your certificate of data. So, this is the user interface on how to add products and collection. This is only one way to add the products. There would be also option for batch uploads or using the API. But if you just want to add 1 certificate, you have a code like this where you provide the product details, including the ID and you can provide additional ID as well. You'll be required to provide 1 of these. You also provide the product description at the top. You can see you have a testing and attestation tab. So, as you go through it, you will. Add your manufacturer information, testing information and then attest to it at the end and we build it in such a way that it's user friendly as possible with drop downs. Our pop up windows when you have to select the certificates, sorry, the citations, for example, if you use a CPC, sorry, if you're providing CPC, you would. You need to provide the name of the credit laboratory. I would, since we already managed that data, it would just be an ID field that you would enter. You don't have to provide the full information and. The business accounts in each business account you have, we will essentially save the manufacturer some lab that you have provided previously and so you can reference past many factors or labs that you have to repeatedly provide that information. So, editing products in a collection, this is how. How the screen will look you have each row will be different certificate, it was a different product of this drop down where you can see product details, manufacture details, testing details. I mean, this still is a little bit subject to change, but this is a concept right here and it. Where again, this product collection, if you wanted to add. User to be able to provide to upload data such. Maybe this user could be a broker in the upper right, you see another button, so invite a user. And then you'll get this pop up where you have an email and then you can select the role in this case, an editor, but you could also have. Well, is that is that limited to just like a read or just providing the data, but not being able to add it. And then this point open it to discussion if you have any questions, please raise your hand. I'm just in here. Well, also be. Review, or sorry, the chat box and reading off any questions that may type in, but I do encourage anyone who has questions to speak up. Please raise your hand and Justin will call on you. And then there's a second poll that asks about your interest in purchase of painting. If you're willing to answer it, please do. And then we'll reach out to you in the future. But if you are. Need more time, you could. Do this go to our website, cpc.gov or email us at e-piling pilot at cpc.gov. I'm going to go back to the previous slide. Justin, you can start the poll and then we can open the board for questions. Just so you can read off. Sure question. So the 1st question we have in the chat is, can you touch on the numbers being provided to the test participants? Yes, so in advance and I hope. Soon, when we publish the Kater, we provide the codes. Most of these codes are codes that we currently actually target off of. And these codes would include any product that requires a certificate. If you are curious, you can go to our website as of now and browse there and find the product. List that all products require a certificate. There are some pages in the small business, and what page. Where you can find that information, so we have another question. The next question is, will there be a requirement to transmit any. Certificate information on which the final cpc slash is based on. That's a very question. So we are focused on the final product. And so, if you are using component part certificates to create that final certificate, you would provide that information. In the product registry as well in the message, the full message site of the opportunity to provide multiple. Or at least multiple labs and the citations for each class to save the product. They have you created from multiple, you have multiple certificates. You could provide all of that if. And if you take the other approach and just do a final test on that product. And have a final test report, you could just create a certificate off of that final test report. So, just to kind of quickly summarize, yes, multiple options. Excuse me, you have multiple options to provide that lab information. Next question is, if I have 1 product with multiple manufacturing dates in 1 shipment. Will the filing allow me to enter a range of dates or do I need to do a separate filing for each manufacturer date? That question seems very nuanced and don't quite think I could answer it directly in most scenarios. You should have 1 certificate or product where that where we would. I think the position that if it's, it's a product manufactured on that date or in that run. So, if you're referring to products every, you know, are manufactured over a run over a series of days. Yes, that all would be considered as on that could all be placed on 1 certificate. That's how it currently stands. And in that scenario, you just, well, we only are really requesting the month and year of manufacturing. So, in that case, just have to provide a month and year. We do would have the option where you could provide like the lot number 2. Again, that's an option that's more for your purposes to keep track of. But if this is a question more about like batch manufacturing and repeated manufacturing, that's something we will address as part of the data pilot and answer at what point. Would you be required to submit a new certificate for that product? And to what extent can you include multiple batch runs over a series of weeks on 1 certificate? The next question is currently CPC hold. Sorry. Currently, the CPC holds do not prevent entry shipments from moving to the final. On signee, yeah, well, the new process be a stop such as current FDA reviews. You have LPA holds, etc. I know. So. To the 1st part of that question, that is absolutely true the under review message does not it's not a whole issue into your shipment. Can't go off off premise to the consignee just can't enter commerce until the review message. For the clock runs out, that's why we're testing to show a new period. So. You could take those products and your commerce is earlier than under the current. A review period and we will not be. What you suggest about FDA, we're not going to take that approach. We're not changing anything in our enforcement health certificates. We are currently, we will continue doing everything the same as we currently are. Next question is, can CPC define what products they classify as high risk? That's a challenging question to answer because we don't. So, we're looking at more so a substantive violations. And so we're looking at stuff like ladder valid. We're looking at playing mobility. We have a lot of regulations surrounding children's products. And so, like. We're not particularly looking at. Like specific products per se, we're looking at like. Products that may have certain violations are more likely to certain violations and I can't really tell you that top of my head. And as part of our risk assessment, we also look at. Like, where the product, where this comes from country in origin, each TS code. And I can't really answer for them that I just don't have that answer. I'm still here if you want to ask any more questions, we're still building them. We have to end of the hour, but here is our information or contact information. I will make this hour and this recording available online as soon as possible. So, you can review it and share with others. Again, I want to encourage your participation. We hope that you see this as an advantage to you as well. I go back and look at the benefits that we are offering. And ultimately, we will be making this into turning this into a final goal, but we want to work with you now. We're able to iron out all the things and work with you. So. You don't reach a point where you very quickly have to meet this requirement. We sell plenty of time. We reached that point. So please work with us now. And provide feedback to make this defiling as seamless as possible for all in quarters. Okay, I have another question. Yep. Next question is, can you clarify how all clothes will work? Yeah, so that would be using a file. We'll give you a template and just. We're using versus some transition that data into a CSP. Um, and there would be a field on the product registry where you. Up below that file, and then you will have an opportunity to review. There also be check and built in. So the system would automatically check and you have the correct data and the correct format and. Flag any certificates that have errors, and then you have the opportunity to correct those before you finally. Actually, like import that data into the product registry. Next question is, if we, if we file you filing, will we have to include the CPC with the shipment? That's a very good question. We are currently reviewing the regulations for 11 and 10. And of course, you finally go back then and that is the. Citation that we will be updating as part of the rulemaking at this moment, I can't really can't answer you directly. And so, but hopefully in the future, near future, once we start to work on the rule that. Can't you that answer next question is, are you able to are you able to share details on fees or fee ranges for 3rd party certifications and the time it takes to get 1 issue? I do not have that information. Notice anyone CPC, we don't deal with any. These information and so the question is related to accreditation. Laboratories is that what? Sorry, Justin, is that some questions about accreditation? So, the 3rd party certification certificate. Okay. So, yeah, we do have the requirement for 3rd party testing. You could go to our website and find information there. We also have a search function where you could search for laboratories. In your country or where they're manufactured that are accredited. For children's products where you can conduct the testing and at that point, you could do your own outreach to them about costs and fees. If it's a general use product, it does not necessarily have to be an accredited laboratory. You can do testing in house even as well. Next question, next question. So, to clarify, there are 3 options for transmission 1 of 1st, single product to. Book upload 3 transfer of information. Yeah, that's for providing information, the product registry. That's exactly right 3 options right there. Next question is, when do you anticipate being able to provide the and not just product description? I hope so, we can next month, when we finalize, if it's air and publish that. Uh, then I would hope to also publish the list. And so, we're still. And if it's not the full list, it would be at least a preliminary lesson to work off with and then we may provide it update later. Next question, will brokers be able to have multiple importers under their account? Okay, so actually the product registry will work in the reverse. So, the accounts are based on the importer and they're able to invite brokers to assist them in uploading the data into the registry as a broker. You're able to work multiple importers. So this, you did not see this, we haven't yet created this. But as a broker, once you get access to the registry through 1 importer, and then you gain access to others, you will have your own essentially your own interface, your own account information. So, you essentially your own screen that would show you to which product collections you have access to and that that's the approach we're taking is of course, the certificate data is owned by the importer. So, as a broker, you would see, like, I'm working with this importer a for these collections, I can submit data and then I see broker importer be and I'm able to provide data and then so on. So, as a broker, Arthur will be able to see all of the accounts that we are doing work for under 1, say, login, for example, we won't have to have like separate logins or go in and out in order to access information for different importers. Yeah, so you just have 1 log in exactly as you said, and you'll be able to see with which importer is you're working with. Great, thank you. Next question is, if there are errors in data transmission, we'll see PSE notify importers. Yes, we will test the morning flags during the pilot. And so we would so, of course, if you provide the data, you would receive a warning and then we'll we'll figure out at what point, like. What are the business roles as well? And. For example, if there's formatting issues, or if there's or just like compare data fields and they don't match, we will inform you about those issues so you could correct that when filing and we will also. Publish this business roles in advance is CPSC working with other PGA's not just CBP. For example, if the product is a non medical device subject to FDA and CPS. We're not working with other agencies that extend only primarily working with CBP, but I wrote that other J message sets to get ideas to create filing. I am like a scenario like that. I mean, we wouldn't be sharing the data you provide with FDA if that is your question in the end, but it would end up being your responsibility as the importer broker to know for which agencies you file a message. And then just a little bit of added information because I'm not sure where the question is coming from, but each PGA is a separate standalone message. Yes, and given the CPSC product jurisdictions, there is very little overlap, I would say between other products and FDA, but I don't think you're going to perceive many scenarios where you have to submit 1 or 2 PGA message sets more than 2 PGA message sets. Is there currently a cut hair covering CPSC data elements? Not yet. That's the thing I want to finalize as soon as possible. And I hope by the end of this month that we made available on CBP's website, the working group of 9 has already reviewed it, provided comments. And so I'm just incorporating those comments. Many of them are just clarifications and small edits. And once that is complete, I'll ask CBP to publish it on their website and also include it on CPSC's website. Are there any intent to have another session like this? Maybe as we get a little bit closer and the cut hair has been finalized and people have had a chance to review it? Possibly. Hey, I mean, I'll be open to having another session like this, but I haven't planned anything yet. But we are to that point, I'm really encouraging anyone on this call. To like ask your participation, because we are we are really trying to finalize the numbers and the number of participants because. Relatively soon, we'll begin the training and provide guidance materials. So. At a certain point, we do have to cut off, but that's not that won't be until a couple months from now. So, my hope is after this session that you could talk internally with your team. I consider the material provided today and we'll monitor what page and get back to us as soon as possible. With a willingness to purchase a page. Hey, well, we have a question. This question is, is there a limit of entries required per month? For example, to be considered. No, we'll take anybody we actually want to get a pretty broad that of importers and brokers. So, we're looking at in personal sizes. Importers that they're from those of transportation of certain products. Because we see that each of you have a situation. Different means of maintaining your certificate data. So we truly want to get our numbers to even pass 30 if you want to. It has all these scenarios and many of them is still, they're still unknown for us. But the larger group we have, I feel there's a pure risk of running into issues during the beta pilot. Well, at this moment, I'm going to stop the recording and I. Finish before the hour, and so I want to thank you all for listening to me speak and. I hope I can visit you to purchase the date with us. So thank you once again, and I hope to hear from you soon.