 All right. Good morning, everybody. Welcome. I want to welcome everyone that's attending our e-filing workshop virtually and here in person at the CPSC hearing room. We're really looking forward to today's meeting and being able to walk through the e-filing project, give an overview of where the project is and where we're going and in particular our beta pilot. So speaking of the beta pilot, this is not the last time you will hear this today, but we need you. We are still in need of volunteers to participate in the beta pilot, especially importers, because the importers will be the companies whose certificate of compliance data is filed and that we will use to analyze as part of the pilot. So, as you're listening to the, to the meeting today, please think about whether participation in the pilot would work for you because we really do need you. It's critical. Trade participation in these things is critical. We want to get this right. We want to make sure that we fully test the pilot, the infrastructure, the processes before we move to a final rule and then final implementation. So please consider volunteering. In short order, I'm going to, we're going to turn the floor over to Arthur Laciak, who is our e-filing program manager. Many of you have corresponded with him via email or received emails from him. So he'll sort of formally walk through the agenda and get our, get our day started. But first, we are very honored to have CPSC chair Alex Hoensarek with us today to provide some opening remarks and I'd like to just introduce him very, very quickly. So, Alexander Hoensarek was nominated by President Biden on July 13, 2021 and confirmed by the U.S. Senate on October 7, 2021 to become the chair of the CPSC. Prior to joining the commission, Mr. Hoensarek was chief counsel for communications and consumer protection with the U.S. House of Representatives Committee on Energy and Commerce. In this role, he served as the chief legal advisor to chairman Pallone on the committee on consumer product safety, auto safety, consumer protection, privacy, broadband and other communication issues. During his tenure, Mr. Hoensarek was instrumental in oversight of consumer product safety matters and drafting legislation to increase the authority and resources of CPSC, which we always appreciate. So, chair, please. Thank you and thanks to everybody for joining today, both in person and virtually, I got to meet at least a couple people on the elevator right up this morning. So, I was hoping that you were able to find the coffee and get, get a cup before you came here. But I was also encouraged to see the list of attendees and see the wide range of expertise, both governmental industry that it represents. Because in the current trading dynamic, it is critical for CPSC to keep evolving to be able to best target hazardous products as quickly as possible as they're coming into the country. E filing certificate of compliance is a critical initiative here at CPSC. We get it right. E filing will enable us to target shipments that put Americans at risk. Well, let me step back and allow us to target shipments that are putting people at risk as quickly as possible. But at the same time, allow shipments who have good histories of safety to be able to move their products quickly through the ports. You know, when it's up and running, E filing will improve our targeting enforcement capabilities by incorporating certificates and compliance data into our RAM assessment methodology. And by collecting that certificate information electronically, compliant cargo will be facilitated. We're going to be able to check on the certificates electronically as the products enter the ports as opposed to when a product was stopping shipments and taking a look at it physically. CPSC staff of the ports are going to be able to target substantive violations and look for things like lead and phthalates as opposed to slowing down some of the commerce that we see at times. Doing our job as we need to do it, but without the electronic filings makes it more difficult makes it slower. This is a multi year project the CPSC has been working on, but we've had a alpha pilot already and there's certificate of compliance study and both these have supported the benefits that this project will have on CPSC's import targeting. The next stop after this workshop is Jim's talked about is the beta pilot and it's going to further test the E filing system and inform our rulemaking going forward. Those of you who are industry representatives, as Jim has said, and I think you're going to hear again and again throughout the day, we're going to urge you to participate. And for those who have signed up already, I want to thank you. I think that is very important for the work that we're doing and appreciate that. For those of you who haven't signed up yet, I encourage you to do so and think about it. Because by volunteering, you can have the opportunity to test the filing as well as ability to provide feedback on the PGA messaging set and product registry. As I mentioned, we are going to be moving forward with the rulemaking and this is a great chance for you to have an opportunity to have early input on that process. The more firms that participate, the more we're going to learn about how to make the E filing system work successfully. And of course, firms that volunteer will be able to have a direct impact on the direction that E filing takes. For now, I just want to encourage all of you to actively participate in today's discussion. We want to learn from you. We want to learn from your expertise going forward. And I look forward to discussing the outcomes of this workshop with staff as we discuss where go next with the beta pilot and with the rulemaking. But before I turn this back over, I do want to take a moment and thank the CPSC staff who have been working diligently on this, not only putting together today's workshop. But also, as I said, for years working on the E filing system. So thank you very much. I appreciate all of the work that you've been putting into this. And going back, thanking all of you as well for being here today and for hopefully engaging them in the beta pilot as well as providing more information for us as we go forward. So thanks again, and I'm going to turn this over to Arthur, I believe at this point in time. Welcome everybody. Thank you for joining us in person or virtually. I know for many of you who woke up and saw the weather this morning was probably thinking, why did Arthur select this day of any. But I can't predict the weather 2 months in advance. So thank you for coming and thank you for your remarks chair and thank you Jim for your remarks as well. And let's begin. So just some housekeeping notes. This workshop will be recorded and will be transcribed and it will be. Trans the recording will be available later at CPSC dot gov. Or if you're an in person attendee, please make sure to sign in at the front door. At some point today and pick up any of the papers at the front door. Wifi is also available if you're here in person. Of course, bathrooms and water fountain in the elevator lobby. There is a map for lunch places during our lunch hour. So the agenda on the agenda today, I will provide a brief overview of our history of e filing what we have done in the past and our hopes for the future. And then I'll later pass the mic to our 2 compliance investigators cat rickerson and Hector. Ramirez who will be providing an overview of our current certificate requirements. Then I'll pass the torch to John bless your international trade specialists who will provide an overview of our risk assessment methodology and our targeting efforts. And then I'll go in and provide a very detailed overview of the beta pilot itself. Starting at 11 p.m. or sorry, 11 a.m. We'll have 4 sessions where we'll have opportunities for the audience, both in person and virtually to provide feedback. I'll be addressing for individual topics. The 1st 1, the PGA message that data elements themselves. The 2nd, the product registry features. 3rd, the HTS codes, his claims and exemptions. And lastly, the minimus and directed consumer shipments. I will CPC staff will provide a brief overview of each topic will provide some questions that we would like feedback on or just general comments. Again, you have the opportunity to. Provide comments here in the hearing room or virtually I'll provide directions later later on. And. And you will also have the opportunity to provide any additional comments. Through regulations of I'll provide that link at the end of this workshop. So. Right. So, I'll just begin on our e-failing program overview. You may have heard me at different trade events or at virtual events. So you may already know what he filings all about. But I'll take this opportunity to repeat myself. So he filing is essentially our PGA message set. It is in order to electronically collect the data elements from the certificates of compliance and incorporate that into our risk. Method risk assessment methodologies. So, why are we doing this? So, for 1. As a procedure now. We have now have a we can't use the risk the data elements from the certificates for actual risk assessment and targeting. Our investigators only view the certificates once they place a hold on the cargo and then open up the cargo and request the certificates at that point to certify or verify that the certificates are valid. So, in that case, we don't actually use the certificate data elements, but we instead we want to incorporate that into our risk assessment methodology. This will improve our targeting and enforcement efforts. And as a chair mentioned previously, it will allow us to focus more on substantive hazards instead of searching for certificate violations. And in our book, a substantive hazards or something like lead, phthalates, small parts, sharp edges, the list goes on and on. We want to focus our risk targeting on those elements that show proved to be a physical hazard to the public, especially children. And move away from targeting cargo for administrative violations such as certificates. So by you incorporating those data elements into our risk assessment methodologies will be more precise and be able to target. Hazardous shipments more precisely. Here's a brief overview. So in 2008, Congress passed the Consumer Product Safety Improvement Act, which required importers to test and certify children's and other general use products and provide certificates upon request. That was codified under 16 CFR 1110. This act also provided us the authority to require the electronic filing of certificates. In 2013, we issued a notice of proposed rulemaking that among other things would require the electronic filing of certificates. We placed it on pause for in order to conduct several studies. Also, CBP was not ready at that point with ace. So we postponed that rulemaking in 2016. We conducted an alpha pilot with eight participants that tested the pj message set and the product registry. We found it to be a great success. And we received positive reviews from our participants. The alpha pilot is the basis for the beta pilot. We are keeping many of the same elements the same. And we're just branching off from there. In 2017, we conducted a certificate study that analyzed the risk of potential certificate data elements. In this study, our investigators transcribed the data from the certificates that they collected at the ports incorporated. And then we had a team to conduct some data analysis to actually look at which elements lead to increased risk of a potential violation. We also found that there was increased risk if a certificate was not provided at all. And lastly, our commission in 2020 unanimously approved our staff briefing package to continue with e filing and to conduct the beta pilot. So let me continue and discuss the alpha pilot results. So as I mentioned previously, it was only with eight participants, but we did have over 1200 products in our product registry. There was over 15,000 message sets transmitted into ACE. Most of them were using the reference message set. I will go into more detail the difference between the reference set and the full message set. This was a pilot that lasted six months, which would be similar to our beta pilot and we did result in an error rate of less than 1%. So what we found from the study is that providing the additional data elements did not significantly affect the importer's operations. Participants who chose to automate data collection and data entry did experience an initial it investment, but the ongoing entry costs will were reduced to be negligible on a per product and per line basis. We expect the same results for during the beta pilot. For participants who experienced delays and errors. That was a result in many cases of the code delivery from the software vendors to the brokers. That is 1 of the reasons why we want volunteers to participate. As early as possible in the beta pilot, especially starting from this point on. We have 1 year to prepare for the beta pilot. So the earlier. A volunteer a broker and importer could get on board with us. The more time will have to iron out any kinks and. Make sure e filing is successful. We also found that there were some errors in reference to the reference number from the product registry as it was transmitted or inputted into the pj message set. We're going to take the results we learned from the alpha pilot and incorporate it into the beta pilots. We don't run into similar errors. Also briefly address the certificate study results. As I mentioned, so on these next 2 slides, I will provide you some charts and to provide some background as to why we want to collect the certificate data elements. As a side note, though, you could go to our web page where you could read through the whole certificate study. Report as well as the alpha pilot report. I'm only providing a very brief overview, but there are many more pages on our website cpsc.gov forward slash e filing. On this slide, it shows 2 different 2. Very important risk factors. So for 1, we found an increased risk if a certificate. Did not accompany the shipment and was not received within 24 hours. Or if a certificate. Was never received after being requested by an investigator and that is compared to a certificate accompanying the shipment. So if you see the red line, the first was very low if. Sorry, the risk was very low for substantive hazard. If a certificate accompany the shipment. But if there was no certificate provided that risk increases almost up to 5 times more. Of a greater risk of a substantive violation and that was in the last column if a certificate was never provided. We also found when comparing the manufacturing date and the lab test date. An increased risk. We found that. Certificates with a testing date. After the manufacturer dates were more than 3 times more likely to have a violation. So if you look at the chart on the right. The dark blue is a testing date after the manufacturing date as you can see it. That certificates with a testing date after the manufacturing date counted for over 50% of. Product violations and that is significantly different when you look at the column on the left. Where the majority of certificates with no substantive violation had the man, the testing date before the manufacturing date. I do have to note that this. This is only a factual finding of the study and does not indicate compliance with. Or violation of the commission's testing regulations at 16 CFR part 1107. Compliant testing regimes depends on each manufacturer's testing and manufacturing scheme for which they're required to have appropriate documentation. Staff did not assess whether firms with violative products were otherwise compliant with the commission's testing regulations. To continue looking at very specific data elements found on the certificate. We found increase increased risk of a substantive violations. For certain manufacturing cities, the data here is anonymized. As you can see on the far right or sorry in the chart on the left in the far right there are 2, there's 1 city in particular that had a much greater risk of a potential substantive violation. Although our sample size was small, we still found this to be significant and using the data we will collect in the beta pilot will be able to analyze this. Deeper and try to find a greater correlation. Also related the chart on the right. Whereas the violation violation rates by laboratory. We again found 2 labs that had a risk of a greater risk. Excuse me of a potential violation. So this is very similar to the manufacturing city. All these labs. Although there was a small sample size, all these labs did issue at least 20 certificates during the alpha pilot. And as you can see 2 of them had rates of at least 20% violations. So we do find significant risk there and 1 of the purposes of the beta pilot is to study this more. And then lastly. In December of 2020, the commission voted for 0 to implement the staff's recommendation for you finally. I will go more detail about the specific elements, but it could be broken down into 3 points here. So we are only going to focus on our priority. HTS codes, which is approximately 300 HTS codes. These are HTS codes that. Primarily, the codes. Sorry, these products would be the ones that require a certificate. We'll go more detail later on the session regarding the HTS codes. Second, the determining the data requirements. So the commission agreed that we will select all fields with potential risk targeting value. So these are all the same data elements found in the alpha pilot in addition to 2, which are the manufacturing date and the lab test date. And lastly, we plan to to update and maintain the product registry is done in alpha pilot. When we use that in the alpha pilot, we got really great review. So we're going to continue to use that. Alright, so I'm going to pass the torch to our investigators right there. Kat Richardson and Hector Romero. They will be providing you an overview of the current certificate requirements. Good morning everyone. I'm Kat Richardson and this is Hector Romero. I'm here to talk about our current certificate requirements. The products that must be certified is any product that is subject to a consumer product safety rule ban similar rule standard or regulation. And which is imported for consumption or warehousing or distributed in commerce. These are the items that must be certified. Certific, certification is ultimately the responsibility of the importer. However, importers and manufacturers should have a clear understanding of exactly which standards need to be met. Foreign manufacturers suppliers should insist on a list of mandatory and consensus standards to which they apply. So that's something that we deal with a lot with foreign manufacturers. There are 2 types of certificates. We have what's called a children's product certificate, which we call CPC and a general certificate of conformity, which is a GCC. The CPC is only for children's products, which are primarily intended for children 12 and under. And the manufacturer importer certifies that it's children's product complies with all applicable children's product safety rules, bans standards and regulations. The certification of children's products must be based on the passing test results of 3rd party testing. The 3rd party testing laboratory provides the testing service and results, but does not issue the CPC. That is the responsibility of the importer. For general certificates of conformity, the manufacturer importer is stating that it applies with all consumer product safety rules. A GCC must be based on a test of each product or a reasonable testing program. These are the elements that a certificate must include the identity of the exact product and no others. So we need to be able to ascertain that that product is the product that is in front of us for examination. So it has to be very clear. The part of the party certifying compliance. That could be the importer or the domestic manufacturer. It would have to include the name address and phone number. Then the citations to each applicable CPSC rule of regulation to which the product is being certified. In most cases, there will be quite a few citations that will need to be on the certificate. The date and place where the product was manufactured. So for the date purposes, we need at least the month and year for that. The name of the laboratory along with the place and date of testing. And sorry, and the contact information for the person who is maintaining the test records, which would include name address email address and phone number so we can contact that individual. Pass it over to Hector. Good morning availability of the certificates certificates must accompany each product or shipment of products covered by the same certificate. A copy of the certificate must be furnished to each distributor or retailer of the product. It's not it's not a requirement to provide to the ultimate consumer. It doesn't necessarily need to be a paper copy. Mostly it's electronic. A copy of the certificate must be made available to the commission and to custom CDP UP requests. Third party testing for children's product certificate is based based on testing by independent third party laboratory that CPSC has a set to perform the specific test for each applicable children's product safety rule. And we include the link for that is in our webpage for generic certificate of conformity or GCC is any laboratory and in house or external third party laboratory can perform the testing require. And this is for non children's products. Here you have the list of the products are requiring requiring children's product certificates and products requiring in general, certain certificate. You can see here. And now I'm going to pass to. Yeah. Good morning everybody. My name is John bless here. I'm an international trade specialist with the office. I need to bring this up. I'm naturally loud. So, you know, sometimes having a speaker right in front of me might be. Overwhelming and I wanted to review. What our risk assessment methodology is and specifically. As it involves a filing a lot of this information. Is critical for our targeting and alignment with the exam efforts that our compliance investigated doing out in the field. This provides a lot more information. And as was specified by the chair and others. This allows us to facilitate. Legitimate cargo and differentiate and get much more specific with the. The more risky product as Arthur had identified in our studies. So I'm going to review our system review the overall approach to our response. To the legislation and and. Pretty much the the founding legislation for this was the section 222 of the improvement act. Of 2008. Again, I'm going to read this. We have a bit of time here. Specifically, we're trying to find consumer products that violate health and safety rules. That are not accompanied by a certificate. That are eminently hazard. We'll talk about that in a second. Create a substantial product hazard. Or are from a manufacturer in violation of record keeping requirements. Now, he filing is as was described by Arthur. Specifically, we're looking for those that are going to have mandatory standards. For which we're going to be requiring a certificate. So imminent hazard declaration, which is under our 15 J is not going to be. Those HTS codes are not going to be part of that part of this review process, obviously. And substantial product hazard determination is for our. Non regulated products. So those are not going to be addressed under E filing, but he filing addresses our capability to do the 1st to. And the 5th 1. So. Now under 222 within the required legislation was the statement that we need to. Work with customs and border protection, their itds effort international trade data system effort. Which is the health and safety agencies, how we are going to line up with the ace modernization over time. We need to make it part of our it modernization effort. So, as we modernize our tools within the agency, as we work through our systems development life cycle. We are going to be, you know, integrating a lot of these efforts as best we can depending on funding. And capabilities at the time. And then we need to work with. CBP as well as the trade community. And as well with other PGA's and trying to identify the best ways to. I find those and examine risky shipments. So the philosophy behind the overall risk assessment methodology. I like to summarize as total risk management at import. It's kind of. Catchy at least in my mind that what we're really trying to do is to monitor the overall importation of goods coming into the country. Okay, so the expectation is through the monitoring of the shipment activity by product entity. And port region. So what we're looking for here is good product identification. Specific entity identification, which can be challenging and the current environment that we're in. As well as knowing where and when the product is coming in. We want to be able to get to the appropriate product. We also then match that up with our violation history on the same thing. To be able to optimize our folks responsible. The idea is if we understand the risk at the ports by certain actors for certain products. We can spend our time in those areas and avoid others that are that are lower risk. Some product areas that are great examples here. Our all terrain vehicle product area the program that we have. There's only so many people that are importing those into the country. We do recognize the importing community. We are able to review that importation regularly with them. And if others bring them in, we recognize who's participating with us through our ATV program. And so in that instance, the ATV is not only are they managed in terms of entity, but they're managed very well in terms of the HTS codes that are declared. We got that under control back in 2011 when we worked with the ITC. US ITC to to segregate those out and have those declared separately from small vehicles. A high complexity area is toys. Everybody's importing toys, you know, grocers are importing toys. Every store that you're going to have is going to have toys sitting somewhere. I was just at the at the food market the other day. And as you're leaving, you've got the little toy cars, you know, two for $3 that are just sitting. Everybody's got them. Everybody's bringing them in. And there are tons of manufacturers. So the product area itself and the wide range of types of products and risks that are being introduced based off of the toys makes it a tough area for us to as an agency control. So that one's more of a, we have to have a different methodology than we would for ATVs, for example. I think our audio issue has been solved. Knock on wood. Okay. So when we think of an overall risk assessment program, I want to look at the big picture and introduce you all to the big picture here, which is that we have to have in place memoranda of understanding with with agencies for which we're working with. For example, Customs and Border Protection. We have to tell them how we're going to work. We have to explain to them our expectation given our jurisdiction for the information that we collect. We have to work with them to optimize the situation so that they get the best response from our work that they can in cooperating with us in terms of seekers and working on those violations. So these memoranda of understanding are important and we keep them up to date as best we can and as required. Another component is that we co-locate staff. You've got to hear from Hector and Kat, who are co-located at a couple of our ports. We have many folks across the country working at the largest ports. That's the operational component and it's our need to get the information to them adequately and timely that this effort is really trying to help optimize. And this is one of the components necessary for that. Ours is a different flavor, but many other health and safety agencies are utilizing the same technology today to be able to get the information that they need on documents. We are just operationally using the information in a potentially a different way, a little bit more like an FDA model per se. And then we have other improvement projects that we work on within our overall risk assessment methodology. They include trying to understand those darn HTS codes. I don't know if you've gone through that 3,000 page monster, but they update them, they change them all the time. It's called master data management, the overall area for the product area. But that's one element of just trying to make sure that our jurisdiction and our risks are cleanly identified as much as possible and trade in terms of notification that these are the product codes that we really want. And then you can expect these products to go under review at a high rate or at a medium rate and we'll try to stay, you know, out of the way for ones where it's under our jurisdiction, but we don't expect, you know, products with mandatory standards to actually come through. So I want to highlight one of our gems of cooperation that we've got here at CPSC, which is our participation at the commercial targeting analysis center. We have an effort which we are meaning. We were the first agency to sit down with CVP at the CTECH at the fusion center. Through that fusion center, we have access to additional information to help us understand what's going on with the high risk areas, but it also allows us to better study process improvements like e-filing. So we'll be using some of this data maybe to help us in retrospect double check the information that's coming through. Recognize that through that mechanism, we're targeting using CVP tools and we're using automated targeting system at CVP to get at the worst defenders and to be able to work in areas where we're trying to be prospective, trying to get improved control in certain product areas. So you'll see some CPSC stops coming straight out of ATS that are going to be potentially the messaging is going to be a little different than what you would have coming out of our own system. We have co-located staff, which we've talked about. They are on the ground and in hand with CVP will not holding hands, but hand in hand next to, you know, working together getting to those shipments where they're doing X-ray fluorescence phthalate testing. They're doing mechanical use and abuse testing physical assessment. They're reviewing documents and they will collect evidence, investigate local and you will hear directly from them as needed to conduct examinations. So when we talk about certificate review, e-filing, that's going to obviate potentially some of the requests that you would get and some of the delays that you would get for people asking you to provide certificates at the time. If you provide it electronically, we don't necessarily need to see the paper if everything's lining up. That being said, there still needs to be a certificate, you know, attached until otherwise stated. We actually call the ITDS RAM system. It integrates our available risk information to model and support commission enforcement strategy involving product hazards and importation. So we're collecting shipment information directly from CVP. We have our own CPSD case history, the violations that we work through that actually tell us what product areas are having problems coming into compliance. We have importer entity issues, you know, in terms of lack of control that's being expressed by that company with respect to certain product areas. That type of information we have available. We align with CVP as best we can through their case history information as they make it available. We'd like to get more, but, you know, that's something that's going to take time. We also review based off of screening history. If we see that a product coming through an importer is tested clean five or six or ten times, we don't want to see it again. So, you know, that will feed into the model. Injury and death data right now indirectly inform our response. We get that information. We process it through and we prioritize internally to be able to review what products are causing injuries and deaths. And we go after as best we can and as timely as we can prioritizing those products forward with you at importation. And then the commercial information, some third party information that we're looking to bring in would be GS one product code associated information, Lexus Nexus information. These are going to be product areas that can better specify the product that's coming in better identify the companies that are involved and support additional risk. So the system itself, these are the mechanisms that it uses. We do statistical modeling to prioritize project and operations. We provide reporting out of the system to be able to let managers and staff know what's going on. How are things going in terms of your ports in terms of these products? How are things lining up? We have a, I would say a state of the art graphic user interface that our folks can actually interact with to be able to provide timely feedback directly into the system back here at headquarters. And to be able to manage how they're working through entries as they're doing their exam as well as logging the results as quickly as they can in terms of screening. And then the Ram methodology also provides a systematic review and prioritization of products of interest as I've already highlighted. The next couple slides are just going to highlight the general methods and provide kind of some graphics that let you know what the system is actually doing. So in this instance, this is how we're coordinating with CBP utilizing their tools. I'm not sure if the graph of the graphic can be well read. This is a standard one that's been out there since since, you know, 2010 2009 brokers as the brokers file the information through and through e filing additional information will be provided by the brokers to inform us of what the product is that's coming through. It gets fed directly into CBP systems, which through we have a direct connection which collects that information from CBP ACE, which feeds our methodology, our data system, which then our inspectors get to look at that information directly off the system using the GUI. And through pre planning, which is at the top of the chart there. They can do localized targeting. There's national targeting gets coordinated through the system. And then we know where targeting has not been specifically identified for the day for activity. If shipments come through that the local port inspector is interested in reviewing they can indicate that directly through the system. They notify CBP not necessarily in the mechanism shown. They don't hand a piece of paper, but really what it is is there's direct notification system to system that we're working on this shipment and that we want to coordinate. Then when CBP and CPSC come together, the examination occurs, we do screening, we will package the sample, send any samples that are collected to be found problematic at screening. That gets sent back to our labs for review and testing for confirmation. For the majority that screen clean and we're at about 88% of what we end up examining being clean. Those get sent right on their way. Those that we don't get sent right on their way. They get loaded on the truck and they're off to be distributed into commerce. So this is our general high level view and my last slide here. I want to highlight specifically that it actually is a relatively simple set of steps that we're doing. And E filing is a key component that helps us to identify and differentiate the blue, which is what do we want to examine. Improving the specificity of the product that's being provided and getting direct linkage and identification of the product that's being imported. We can track much better to our history and make better determination on what needs to be examined and get that. Rate of work that we're doing at 11% 12% being sampled up to 15 and 20. And us not touching some of the ones that are in the 88% and saying, hey, we were able to see that that was cleaned through information. We're just passing that on through and so recognize that that the less we're utilizing getting our hands on it in the top. The less time is being spent working on legitimate trade. The faster it gets out into commerce and do recognize this initiative is a critical one for us to get right and will yield. Rate results I think in the long term in terms of CPSC getting out of the way for legitimate trade and getting to more product and optimizing the time of folks like Hector and Kat. This diagram is also one that's out there in the public sphere. Feel free to utilize it. And if you have any questions, these are in a high level that the steps that we utilize and we can talk about each and any of these as you need. So I'll provide a brief overview of the e filing beta pilot. So I'm going to give it like a very quick rundown of essentially what we are planning to do. So the agenda and after we do, after I provide this overview, we're going to lead into these into four sessions discussing specific points about the beta pilot. The first one being the PJ message set data elements. The second, the product registry features. The third, the HTS codes, disclaims and exemptions. And lastly, the minute the minimists and directed consumer shipments. So on those last four bullets. Those will be the opportunities where you and the general audience in person and virtually will be able to provide feedback. So the beta pilot is set to begin in the fall of 2023. We are looking for approximately 50 volunteer participants and this pilot will allow us to test the PJ message set with many more entry lines than in the alpha pilot. Primarily, we're looking at testing the implement implementation processes and procedures on our end and also on the end of the filer. So the broker or importer. And when I say we're looking for 50 volunteers, we're looking for both brokers and importers to participate ideally together because we need to test the PJ message set with real data. So of course we need both both parties working together in order to test this. So how we will, how will CPSU use these beta pilot results. So first of all, it's a scale up our IT systems to be able to accept the data on regulate regulated consumer products. Second to refine the required infrastructure for real time collection. So that means. Receiving that data from ACE incorporating that into our RAM, which John just spoke about and making sure that infrastructure works. Also, we want to test the capacity making sure we have that that infrastructure when it's built out and once you filing does become permanent that we have the appropriate capacity in order to collect all the additional data. We also want to test internal external procedures to supply use and maintain certificate data that would be working with you the volunteers making sure you are capable of obtaining that data in an electronic format and submitting that through your ABI via ACE. And we want to test that with, of course, different product categories, not just children's products or toys as you saw previously. As Kat and Hector did present that there are two different type of certificates and different requirements for different products as you compare general use products to children's products and even within children's products are different regulations. So, so my, so when I'm looking for volunteers, I mean any of you live here in person or listening virtually. If you import consumer product, please volunteer with us. That's my plea. We're trying to get a pretty broad group and diverse group of importers and brokers to participate. We're looking at any importer of any size. You don't we because when we test the beta pilot features, we want to make sure everything works, not just for the biggest importers and brokers, but also the smaller ones who may have smaller teams. We want to make sure the participants are able to collect the certificate data. It is a requirement to have the certificate, but there's, there will be the additional staff to make sure that it is electronically available. And we want to again test it with different consumer products under our jurisdiction, not just for, you know, toys, for example, we want to also test it for mattresses or ETVs, for example. And lastly, this will inform our rulemaking. We do plan to make e-filing permanent, but that will be well after the pilots. And how will this benefit you industry? The probably the most important question of the day. So this, as I said, will improve risk assessment enforcement and trade facilitation on our end. We as e-filing becomes permanent, risk scores will decrease for importers who electronically file valid data elements, resulting in fewer examinations of cargo at their ports. So to repeat what I said before, we really want to focus on substantive violations. We want to shift away from targeting for certificate violations. And so by collecting this data and ensuring that the certificate data elements are valid when filed at entry, we'll have, those of you who file valid entries should expect to have lower risk scores, which results in fewer exams at the ports, fewer days held at the ports. And just, and if there is a hold done, it would be for a substantive violation. So we are, here are the seven data elements that we are collecting as part of e-filing. Most of them are very related to the requirements of the certificate. Later on, I'll go into more detail about the specific data elements. And as I mentioned previously, these are the same data elements as in the Alpha pilot in addition to two. We are collecting, of course, the identification of the finished product, which would be a product ID number, which could be anything that you as a filer would like to use, something like a model number or skew. I'll discuss that in more detail later. Each consumer product safety rule to which the finished product has been certified. The date when the finished product was manufactured. Again, that would just be the month and year. The place where the finished product was manufactured, produced or assembled. The date when the finished product was most recently tested for compliance. The parties on whose testing certificate depends, which would just be the testing laboratory. And lastly, a check box indicating that a required certificate currently exists for the finished product. Again, these are the same elements from the Alpha pilot, but we are not requiring two elements specifically. We won't be collecting specifically the party certifying compliance because that information we could get from the entry documents and also the individual maintaining the records. The last item, which is new, which is actually not on the certificate is a check box. That is just an additional requirement that the filer is. They're excusing that the filer is in compliance with section 14 and 17 of the consumer product safety act. So to provide an overview of how this will look. I'm going to start with option two at the bottom. So the importer or broker has the option to file all seven certificate data elements via ace directly and that will be processed into our Ram. The other option, which includes a product registry, the importer will file those same data elements into the product registry. We want to use the product registry. We actually encourage and we found that like 99% of cases of product registry was used during the Alpha pilot. Because we find that the importers and brokers, of course, if they're bringing the same product over and over again during the same year with the same certificate. Why file the same data multiple times instead use the product registry. You filed that data once and then you incorporate the product registry ID number, which could be any number of your choosing something like a skew or model ID. Something that's easy for you to maintain records of and the broker will file that information via ace. So in that case, we're really only talking about one data element filed at the time of entry and that data will be incorporated into Ram. The product registry is something that we CPSC will develop and maintain. And I'll go into more detail about specific features about the registry and we do want feedback on the registry itself during during the pilot during this next year of development and the pilot itself. So that is another reason that I'm asking for volunteers in order for you to participate and provide feedback on this procedure and the product registry itself. If you use foreign trade zone, sorry, excuse me, foreign trade zones. The PGA message set would be filed at the time of entry. So when you use form 3461 and not when entering the foreign trade zone, but we would encourage to use a product registry. In that case, it would be easier for your for record, record keeping purposes here. Can you hear me? Okay. Okay. Okay. Later. Thank you. So the timeline here. So in this beginning now we will begin it development. As I said, next fall will fall 2023 is when we begin the beta pilot. So starting this fall, we'll have development during the next few months. We'll receive it or a feedback from the volunteers. And in the spring of 2023, we will finalize the development of the PGA message set. The summer of 2023 would be testing of the message set with a first fake data and then real data and then volunteer volunteer onboarding. Once the pilot begins in the fall of 2023. And throughout the six months process, we will receive iterative feedback and the pilot will end in the spring of 2024. And at that point, we'll begin the final rulemaking, which we expect to complete at the end of the year 2024. In the next few months, we'll begin developing the catare volunteers have the opportunity to provide feedback on the catare. We'll be using the alpha pilot catare as a base point for this. As I mentioned before, the beta pilot is heavily using features from the alpha pilot. And copies of the alpha pilot will be distributed to the volunteers who participate and they'll be encouraged to provide feedback. And specifically regarding the PGA message set development. So from essentially starting now into February is when we're us working with the participants will develop the initial draft the catare. A draft version that will be mostly finalized by February. Between March and May, that'll be the time for CBP to develop their the PGA message set and also for the software developers to develop their software for the message set itself. June to August would be certification environment testing. September will be production environment testing. And lastly, in October, that's when the beta pilot will begin. So if you're interested in participating, of course, if you are in the room here in person with me, you could always stop me and ask to participate. If you are virtual, you could email you filing pilot at CPSC.gov. We are looking for importers to volunteer, but of course brokers, software developers and labs are able to participate by dealing with an importer so we could collaborate together. We are also seeking a subset of nine volunteers to participate in the IT development process. So at this point, we are actually ahead of schedule so I would take a break at this moment as per the agenda and that will give us enough time to make sure we have all the WebEx features ironed out before we begin our next session. So, yeah, take your time. And, okay, as we continue on, we have about half an hour for any questioning. If you are here in the hearing room, please just raise your hand and and to my right will pass a mic to you. Please speak into the mic so everyone here and online can hear you. And please present your name and the company you work with. If you are attending virtually, you could type your question directly into the Q&A feature. Please include the company you work with. So we have the record of that cat here will read your question to me. If you would like to and you're attending virtually you can speak up, please select the raise your hand icon. And at that point Hector in the back room will select you and will select you and unmute you and for that period of time you'll be able to speak after you're done speaking, you'll be muted again. Again, please provide your name and the company you work with before you ask your question. This is the first time we're doing a hybrid workshop like this. So please hold tight and thank you for all your patience earlier today. So the floor is now open for questioning. Oh yeah, my colleague John here gave me a good recommendation I should have introduced my team here in front of me I forgot to do that early this morning. So, of course, you heard John, our international trade specialist speak earlier today, Jim Jiholsky, the director of the Office of Import Surveillance. To my left is Andrew Rucker Yarosh, who is the supervisory management and program analyst for our office. You already met Kat Richardson and Hector Romero. Hector is in the back room. And Mary House is our attorney and Anne Hamilton is one of our new staff members at in our office of import surveillance. Now I will open the floor to questioning and I will begin with Michelle back there. Hi, good morning everyone Michelle Pierce. I'm with Ann Derringer and we are a customs broker. I actually have three questions if that's okay. Question number one. You would mention something earlier about the certificate or someone did in their presentation about the paper certificate. Is the paper certificate still needed if the information has been e filed? Is there still an expectation that it's going to accompany the goods? Mary, you want to take that question. Can you guys hear me. So the statute requires the certificate. So that is an open question. It depends on what the final e filing requirement is. So if all of the data elements are collected, then I think through rulemaking, we could say, yes, that satisfies the certificate requirement. If we were to narrow. The requirements for e filing. You would still have to have all of the data elements. So it's an open question. Something that we will. We're testing in the beta. We're giving most of these certificate data elements. So through the rulemaking, we'll have this discussion. People will be able to comment. We'll take in the information. We'll take it under advisement. But that's a possibility. If we have all the data elements, then. Through electronic means, then we may not need. Anything else. So you're coming about the narrowing of the debt elements. Are you considering then not taking in all the data man? Not taking out data pilot. We're going to be doing a rulemaking. People may have comments. I'm not saying yes or no. I'm saying we're testing it. That's the purpose of the pilot. Sure. That's the purpose of the rulemaking. So. We're, we're, we're thinking about it and testing and that will be determined at some point. Okay. I understand. Thank you. My second question will if filing become mandatory, you know, we have some agencies where like FDA, yes, it's mandatory. You don't have an option, but then you have like fsis where it's an either or. Yes, we plan to make it mandatory and. But we don't plan to do the final rulemaking until after the pilot is complete. So lessons learned from the pilot could be incorporated. The estimate now is end of calendar year 2024 is when that final rule be sent to the commission. Okay. Understood. Thank you. And then let's talk about the HTS, the 3000 page beast that John mentioned earlier. Have you guys completed your combing through of that monster and have you determined which tariff numbers will or will not be possibly disclaimable. Has that work already been done or is that something you're still working on? Used to these. Oh, no, that came through. Okay. So, Michelle. It's going to have to fall within the 2 a messaging construct that we have in place. So, it will be a subset of those HTS codes in terms of the HTS codes that will be part of this. We have to decide how we're going to. Get a reduced volume for the test. So those HTS codes while they are a full 300 and plus set used for 2 a messaging is identified. We have to pick a subset and how broad that subset would be for the test as compared to full production has not yet been determined. Okay, so it's not going to be open to the I've got a list of HTS. We have a list of HTS codes. We don't know yet how we're going to feather this in terms of the test. So there's only going to be certain products allowed in the test that fall under that subset of HTS codes. Correct. Okay. All right. Thank you very much. It will be the subset will be close to the codes you're ready to target in Ram. But we still have to go through it come through it because there's some HTS codes such as like hairdryers, for example, that are targeted in the Ram. But won't be part of this pilot because hairdryers don't require a certificate. So we're going to finalize those details. Okay, so you guys you do then have products where you target but will not be part of this. Right. So there are products there are products for which we do not work. There are products that we target for hazards for which we do not require a certificate. So a great, a great example would be an adult hoodie that if the hoodie comes in. We're looking for children's hoodies for the potential of a drawstring violation, which would be a 15 J. We've got a lot of product codes for which the strangulation hazard can occur on the on the children's hoodies that we're looking for. In those instances, those HTS codes would would not be part of the filing because we're not collecting certificates for those. And if we're as part of the construct going to go any further than just the 15 J that's I think for the team has to make a decision if we're going to go and do a subset of the ones that require certificates. I don't I don't know at that point. Now, now previously we've been unable to obtain a or you've not provided a list of the HTS codes that you guys we will you okay I was going to say I saw a presentation at Westcon where it's had said there was a link to where you could find the HTS codes right. So that link is only to the product categories. Okay, so far we don't have the list of HTS codes published yet. Okay, we will as part of the pilot. Okay. So you on our web page you can find this categories also that nice slide that listed in like type eight font, those are the products that we would include in the pilot. And in the FRN, if you look closely one of the footnotes it does list all the product categories. We will address HTS codes and this claims and exempt exemptions this afternoon so. Okay, perfect. Thank you. I have a question from Adam Lee's geodes which is a customs broker. It says your presentation showed a list of products requiring certs of conformity, regardless of whether they are children's products or general products. Will this list be constant or will it change periodically as new products are identified by CPSC for targeting. Okay, so I'm going to repeat the question. This was from Adam Lee's from geodes regarding that same list of products. His question is, is that list going to change over time. So those lists of products, especially general use products have been identified by the commission requiring a certificate. That list will only change if there is any rulemaking or any decision made by the commission where a product would need additional certificate. Just momentarily. That so in terms of the identification of the products themselves. What Arthur said is absolutely correct, but do recognize that we are not in control of how those get classified in terms of HTS codes. So do recognize that as HTS codes change. The commission has to be able to change the HTS codes that align to this requirement. To be able to hit those products that are part of the certificate. Effort, so the e filing effort, so do recognize HTS codes can change. But in terms of legally what's going to be happening. You have to have a certificate requirement for the product group. Then we have to go get the HTS codes. Those HTS codes can change independent of any types of, you know, authority concerns as well. So do recognize the HTS codes. We'll change a little more often than that asks and in conjunction with Michelle's question about HTS codes. Will you be flagging them as other agencies do. Yes, we plan to. Hi, I'm Diana guild with FedEx trade networks. I had a question regarding the product registry ID. You'd mentioned the importers can go online and register their products there and then they could provide a product registry ID number to their broker. Will that product register ID be the entire e file data set or will it just be a portion of it. So with that product ID. When we input it into ace with that take the place of the full message set or would it be in addition to the message set. No, take the place of the full message set so that reference message set would be shorter than the full message set. So there would still be some data elements they would. So for instance, if the manufacturer varied for the product or the date of testing, they wouldn't file separate project excuse me product registry IDs. For each manufacturer of a product, they would just fill that in in the message set. No, those products that they have different manufacturers would then have to have different certificates. Okay, so the reference number. Yes, so for instance, if you had a customer that was importing a certain toy, but sometimes they have it manufactured at one facility, sometimes at another. Is that information that they would be putting into the message set as opposed to the product registry ID. No, if they enter that into the registry, because the registry will request the information that the manufacturer the lab so that differs that importer have different certificates for those. So they'll have two certificates for those two different products. And so when that is filed a certificate will be filed for each product that comes in. Okay, thank you. I think I have another question. So for each unique combination of product testing date manufacturer result, you know, certification would need a separate certificate. Right. So there, there isn't going to be any sort of crossover. Right. Yes, for purposes of e filing and I was actually going to address this later. Because of how data has to be entered into the registry. We find it only possible that you have a unique certificate for products if there's a substantial change such as a different manufacturer or different lab or date, you have to have a different certificate. Later on we'll go through the product registry features and we have some ideas to make copying and versioning control easier on your behalf and we will like input there. We, I would say we you only have the same product like multiple products on one certificate. If it's very similar like the same model and all the information is the same including the citations. That's right. That's what's happening now. Most people are doing separate certificates and there's we've provided guidance. And so it really shouldn't change that much. I think some people maybe group things on a certificate. But I think a lot of people already understand when they need a new certificate. So it shouldn't be a huge, a huge change for people. Back row. No, back row. Ryan Redford from Amazon. Similar to that, if multiple importers are importing the same product, same manufacturer, probably the same certificate, could they potentially both use the same reference number to that registry entry? I'm not quite sure how we would approach that. That's a really great question. And I think that's something we have to work out before we test in the beta pilot. I think my concern in that type of a situation ends up being the importer control of their product registration records that are in the database. So if you have multiple importers importing the same product, somebody is going to have to be responsible for that information. So the question is going to be who's managing that data within the registry. Right. I mean, technically, the importer is responsible for that information. We have a rule. It's 16 CFR part 1109 that allows an importer to rely on another party's testing and it even allows them to rely on another party certification if they take certain do care concerns. Like they can't just willy-nilly copy somebody else's certificate. They have to ask questions beyond that and the rule lays out what's required. They have to have access to the testing data, access to the underlying information and ask the right question so they know that's right. So each importer would have that responsibility and that's what you're certifying to. So I would expect even if they're relying on the same data that they would be independently certifying because they're saying, yeah, I looked at that information. They're making that affirmation. So even if it looks the same, each importer will be responsible for making that affirmation on their own. Avenue where maybe the manufacturer would be the one to complete the product registry and then supply that number to their importer. A manufacturer could certify, a foreign manufacturer could certify a product, could provide the underlying testing under part 1109. What I'm saying is the ultimate person who's certifying is the importer. So they could have mass data, but the person who's on the hook for that is the importer who's saying, yeah, I checked that information and it's right. So they're the person who's certifying there on the on the hook, so to speak, if they're relying on a third party's information. They have to look beyond it and make sure it's accurate. So potentially more than 1 person could rely on a manufacturer's testing and certification another person's right as long as they take due care under our regulation at 16 CFR part 1109. Okay. Okay. Thank you. Is that better? Okay. So let me start all over again. Hi, I'm sumo rock with FedEx trade networks. And I wanted to ask a question about the timing of the filing of the message set. In, in one of your slides, you had mentioned that the message set can be filed at the time of entry or at the time of entry summary if entry summary and entry occur at the same time. So my question is, are you looking for the PGA message set to be filed prior to arrival at the time of arrival, or are you even willing to accept it if it's after arrival. So, Mary, you can make correct me, I believe, per our statutes, it says we could request the electric filing of certificate within 24 hours of entry. Yeah, maybe a little bit different. So we interpreted that entry entry summary. So when you file your entry information, we asked to also submit the message set information. Right. So, yeah, so it's possible that the goods could have arrived. Like the day before that the entry or entry summary is filed by the broker. It's also possible that the goods could have arrived. After the broker files the entry entry summary prior to the arrival of the goods. So does, does arrival of the goods mean anything to the. The arrival. In terms of the review for the exam process recognize that the data needs to be able to be reviewed by somebody that's in the field and it has to be able to be reviewed by the system. And so if the product arrives and then entry is filed after the product arrives, as you're stating, we're still going to need that window of time that's under the 2 a messaging. That's going to state, hey, we're reviewing this, this data. This is going to be data that's reviewed. Now it's not just entry. It's going to be entry plus these data elements. So, the, the windows are still going to be in effect that we've got within the 2 a messaging environment. So, in an air environment, it would be 8 hours after the ladder of entry or arrival. So recognize that that if entry happens after arrival, you still got 8 because we haven't gotten the data yet system hasn't reviewed it. And our folks haven't had a chance to say, hey, the products here. I want to I want to look at it now. So we need that capability to have that window to be able to say. Oh, yeah, that lab isn't on the list. The system said it's a problem. I want to get on that exam and get on that product before it before it disappears. So, to be able to have those eyes, we need to be able to see the information. Okay. All right. Thank you. Linda Rothfield, Ikea purchasing. I have a follow up to that question and it actually relates more to the release of when CPSC will release the merchandise. Typically, PGA is released during the same period of time customs releases, which is 5 days prior to vessel arrival. Will CPSC do the same? Yeah, so CBP releases before the product gets in the country. I think that we have to still evaluate CPSC's response. And the 2 a messaging can, as it matures, decide if we're going to provide release prior to arrival based off of entities. You know, compliance and history. We don't have that in the books right now. Okay. Thank you. But that is something for us to evaluate. And I think as part of the beta, that's something that we can improve. You know, over time is, is try to give more for warning of clearance for certain entities that prove to be not problematic. Something like that. Yeah, we're not going there. We're not using that. So, so that language is something that we're going to let CBP utilize. They need to develop that program over time. I think you can think of it more if the data supports it, the analytics support it, the system will identify as, you know, a preferential type, type situation. I recognize that CPSC, and I'm just reiterating this. We have domestic authority if there's ever going to be a concern, even for a trusted type scenario or preferential type scenario, we can always get to the product to examine it. At the time that I mean, when it's in the marketplace, we can always follow up if we need to in those environments. That a may proceed in the important environment does not indicate a statement of assurance that this product adheres to health and safety standards. It's only an indicator that the, the, our review period in an automated fashion has been concluded. And we always have the capability to go in after the fact in the domestic commerce to go and evaluate product and evaluated at a later date. As another question relates to a unique situation with FDA, Food and Drug Administration, where they have line level holds instead of holding the entire container, a particular line on an entry is held. And that container is allowed to customs clear moves off site to the imported premises for inspection by the FDA officer. Will CPSC consider something similar? Okay, so I'm going to say my piece and I think Jim and others may have to add to it. We indicate on a line basis, whether something needs examination. It's CBP's difficulty and challenge with the importer and broker to designate whether they need to break out that product and segregated for examination. That's more of an operational question I think for CBP than it is for CPSC. We will indicate it on a line basis and it's that product. If you can map that product to that line and we're going to be able to do that much more effectively through e-filing. You're going to be able to tag that model number and we're going to be able to say now much more definitively at the line level. It's that model that we need to be able to look at in those instances when we indicated a line level that that's what needs to be held. As long as that model is what's being stopped and segregated the rest of it can go. That's a CBP problem and I don't know how FDA solving it. Others can speak to this operationally. I guess I would just add that as a small agency with very limited resources, our sort of operational model is to do the exams at the port. So I think I would say that we will continue that. I think we would like to be as efficient as possible with targeting at the line level. But when it comes to the exams themselves, I do continue to see them being done at the ports and probably in a very limited situation would they be done at the importer's premises. Okay, John, let me just add. I'm sorry. Did you want to we have a few more questions and it is 11 o'clock. So just one follow up statement just real quickly right now the way that it's working just because we don't know where the product ends up sitting. While we do indicated at the line level, the whole entries getting impacted in terms of examination. We recognize that that's a problem and sometimes examination of the product within that entry ends up yielding violations and other products other than what would have been on that particular line. But due to the lack of mapping, you know, hopefully he finally is going to help the situation. I'm going to go to Kat. We have to quit more questions from our virtual attendees and then this gentleman will have the last question before we go on to the next session. I do want to remind you if you look at the agenda, there is a time for open forum at 315 today. So if you have any more questions, please hold them till then. Go ahead, Kat. One of the questions we've received is, is it possible to add more than one third party lab information in one children's products certificate? Yes, it will be possible. And I'll discuss that later on. And the second question I received was, if a certificate is reused, then can you just send the certificate number in the PGA message set instead of sending all the details for the product? Yes, that's the idea of the registry that the importer will bring in same product with the same certificate. So you're able to reuse it until to the point where you have to do retesting. Therefore, you would have to issue a new certificate. Let me add to that though. If you file the full message set on a shipment and you're not using the registry and you're not indicating the registry whatsoever, filing a full message set and then two weeks later you're importing the same product. If you're not using the registry, we expect, we expect a full PG message set again. You have to use the registry and you have to manage via the registry for us to be able to use that optimization of just using the certificate number. So I wanted, I think that answers more fully the question. Hello. Hi, my name is why I'm from IKEA. I have a question regarding to the information and certificates. Would it be an issue if the certificate or the information that we sent over to include additional citation that's not applicable to the product. So for example, it will include citation for children's product, but the product is not a true product. Yes, so the certificate when you list the citations and you are essentially as the importer certifying that this product was tested to those citations. So you shouldn't add any additional citations. So if we, so for a non children product and then we put the citation. So, so what you were saying, you tested that non children product to that citation. Yes, you could do that. Yeah. So anything on the certificate, your certifying was tested to that citation. Okay. Thank you. You might be making a risk. That's the kind of thing we're going to test in the beta pilot. Those kinds of things we're not expecting because if it is a children's product will be expecting certain things and it's not a children's product will be expecting certain things. So it, if that, I don't think that happens a lot, but if it does, it might confuse things a bit. I mean, just a piggyback on that is if you're going to add a citation for a children's product, we're going to be looking for an accepted CPSC laboratory that's done the testing to support that. So, you know, you just would need to think that through completely in terms of all the additional information that may be required. All right. Well, thank you. I will continue on. I just like this question and answer period worked out successfully. These were the directions or it's so not going to repeat myself and I'll continue. So the remainder of this time, it's divided into four sections, as I mentioned earlier, there will be a few slides presented, and then there'll be another period of comments questions regarding the slides I just presented. The first session is regarding the PGA message set data elements. So, first of all, the first element is the identification of the finished product. So we, it should be a unique ID that would be provided by the filer. We would allow for options such as the G 10 the UPC skew model number or any other identifying number, but that would be the responsibility of the filer to keep track of that. That's the idea is here that when you file in the registry, use a number that you are easily able to keep a record of, we won't be providing that ID number. The G 10 in the future CPSC hopes to connect to GDSN and if provided G 10 be able to pull that data from GDSN incorporated into our RAM, but at this moment we don't have those capabilities. So if you're using G 10, you would still be required to file the certificate data, at least during the pilot, if things change over the next year, we will of course keep you informed. The next bullet, as I mentioned previously, one product per e-filing certificate. This is due to the nature of the product registry itself. It will be in purposes of data quality and IT development, it will be just much less complex to only have one product per certificate. As Mary mentioned, most importers already do that. We would allow multiple models as long as all the certificate information remains the same. So across the board, like the lab, the manufacturer, the dates, etc. So if you have two products with two or multiple models that are very similar, just maybe a change in the color or something, but everything remains the same, they could be on the same certificate. And the party certifying compliance is always legally responsible, even if a third party test laboratory or another third party such as a manufacturer helps draft a certificate. Also related to what Mary said earlier, if you're using certificates from someone else, you are certifying the compliance. You can also use parts certificates and incorporate that into your certificate, but again, you are the one certifying compliance on that certificate. There is additional guidance available on our website if you go through a small business and Budsman page. Additionally, the party must, the party certifying compliance must respond to CPSC's request within 24 hours. And although this has been our process for now, although that has been our procedure now that the importer is the one responsible, we would like your feedback whether any other party should be allowed to certify compliance. Next, the contact info for individual maintaining records. This information actually not to confuse you, this is required on the certificate but won't be required for e-filing because typically we contact the broker if we are looking for the individual maintaining the records. So, I'm not a good, excuse me, so typically on the certificate, you're required to provide the individual's name, address, phone and email. And it could be just a position title for generic email, but the individual must respond within 24 hours. Again, though this information won't be required to be e-filed, but it's still technically statutory required on the certificate. Next, the date and place of manufacturing. For the date, we only consider the month and year because we understand that sometimes products are created in batches over several days or weeks. And in that scenario, we only need this start date for the certificate. For the place, it would be, of course, the identity of the manufacturer, including the full address, phone and email. Next, the date and place of lab testing. So, the date would be the month, date and year. And for products tested over several days, we would require only the last date, which is different from the previous slide. So, for your manufacturing date, it would be the first date. The lab test date would be the last date. The place would be the identity of the testing lab, including full address, phone and email. Since we at CPSC accredited third party labs, we also have an ID for each of these labs, which you could find on our website. In that case, if you're, well, in any case where you import a consumer product, you have to provide a CPSC accredited lab. So, you actually would only have to provide us that ID number, not the full information. If you are using, excuse me, for general use products, because there are multiple means of testing for general use products, if you use a CPSC accredited laboratory, again, you just have to provide the CPSC lab ID number. If you're using a different laboratory, you have to provide the full information, including if you test in-house, you would also have to provide the full information in the laboratory, the address, phone and email. Again, that is only for GCCs if you're not using a CPSC accredited laboratory. The last bullet here is something of consideration. CPSC staff would like to test having filers provide a web link to the lab test reports. The reason for this is for the investigators to be able to validate the certificates when reviewing the documents. As the process is now, our investigators, after placing a hold, would request the certificate and test reports from the party certifying compliance, and at that point would confirm and validate whether that certificate is valid and the test report information is valid for the product in the cargo and everything matches up. So we want to consider how we could do, how can we validate certificates at the time when the data is sent to us before placing a hold. This is something new that we haven't approached before, so that's why it says optional in the parentheses, and we're looking for feedback from you, whether this would be feasible or if there's any other means to do so. So the idea here is if we're able to get information from, if we're able to have access to the test reports when also reviewing the entry documents and the certificate data will be able to validate that certificate is from, has been created from those test reports and therefore we wouldn't have to place a hold on the shipment to make that check. Again, this is something optional that we are considering, but we're hoping the participants of the beta pilot will be able to provide input on this and provide us some ideas on how to do so. I do apologize for those attending virtually. You did not see any of these slides, but these slides will be made available afterwards. Also, this recording will be made available afterwards, so, and let me go on to the last slide. That is a checkbox. So a checkbox indicating that a required certificate currently exists for the finished product. This is an attestation done by the individual certifying compliance, so the certifier would attest that the finished product or component parts covered on the certificate complies with the rules, bans, standards and regulations stated in the certificate and the information in the certificate is true and accurate to the best of the certifier's knowledge, information and belief. Some portions of the applicable consumer product safety rules that require compliance such as a certain labeling requirement and exemptions are not subject to testing. So this attestation is an affirmation by the certifier that the product complies with all requirements of the applicable rules, not only those provisions for which there are test results. Sorry, that was a little bit long-winded, but the checkbox just to confirm attestation. All right, and so to conclude this session, these are the questions that we CPSC staff have for you, the audience of this workshop. What additional product identifiers should CPSC consider? Second, would you use a G10 as a product identifier? Third, would you be able to readily provide product description information? That was the second slide here to provide sufficient description of the product. Therefore, investigators are able to validate that that certificate is for the product they are examining. So that could be model name, color, color, description and style. Does the product registry address any issues importers may have with product certification? And would providing the URL to lab test reports be feasible? So at this moment, I will open the floor to any questions or any comments or answers to these questions that I presented to you. And so, pass it to Michelle firsthand up. Every time, do I? Okay, so for example, the unique ID for the product, not all products necessarily have the unique ID. A SKU or a product, will that maybe be optional as long as we're able to provide the detailed description? Or would you have us maybe repeat the same information in the description as the product identifier? So when using the registry, you have to create some ID number. Okay. So I think previous in Alpha pilot, we created the ID number, but then we ran into issues there where the ID number was incorrectly entered into the PJ message set. And that's where we found a lot of errors. So we want to instead test, in this case, where you as a filer would create and manage the ID number. So we'll be open to the idea that you could create just an additional ID number, like just a product registry ID number that doesn't have to be a model number or SKU. Does the certificate currently require an actual ID number or not necessarily? Not necessarily. Okay. Another question that I had. So that checkbox, you talked about earlier how one of the requirements on the certificate is the importer's information. And that is that they're certifying the product. The checkbox sort of just takes the place of that, right? Because you're already getting the importer from the message set or from the entry, right? Passed through. So the checkbox just sort of says, yes, the importer certifies, right? Yes. The checkbox is actively, and this is something I was pointing to Mary. The checkbox is required that the importer either does it or the person who's empowered by the importer fills that out. So you couldn't have a manufacturer go and click that checkbox. If I remember properly, it has to be the importer or the legal representative that the importer allows to provide attestation, correct, Mary? And that's it. The importer or their agent. Okay. So I guess as the broker, we would as the broker, you can click on that checkbox with the understanding that you're providing to do care with the expectation that the importer understands that they are on the hook for what you're clicking. Now you had talked about the labs and accredited labs and them having ID numbers. So will that be an either or we can either provide the full name address, phone, email of the lab or the ID number? Yes, either or. So already on our website where you can find the list of accredited labs already is an ID that we issue to keep track of them. So we advise just to do that because it's quicker and easier and takes up less space. As the broker, we're always looking for the less keystrokes, right? Less, less data elements. You're welcome to put in the full. Yeah. I do make the recommendation that you try to find the ID as best you can because of people, fat, thumb, data entry. Absolutely. Us having to clean up that data is a pain and we'll slow things down. Well, understand, we do when we create the registry, we want because we have the available list, same with the citations that we will provide a drop down list. So that information is already should be coded in the registry in order to prevent the. So if you're using a lab that's not on that list, then it's not CPSC certified is what we're saying, right? If you, which is fine for GCC. Yeah, but if you have a GCC and you tested at it accredited CPSC accredited lab, you could just also just provide that ID number. You don't have to go through the steps of providing the full information. And also to that point, many laboratory companies have multiple labs in different countries. You have to provide us the correct one, not just the name of the lab, but like the location and we will clarify that in the registry so it's as clear as possible for you. Sure. And then your, your request for the URL for the lab test report, are you considering using DIS to actually upload a copy of the report or are you pretty much you're just looking for a link. So we're open to different ideas. We could consider DIS and I know that investigators when they request the test reports sometimes submitted to DIS, but we understand DIS is an extra step in the process. So that's why we came up the idea about URL if that's plausible, but we're considering other ideas in order for our investigators to get access to the test reports. At the same time, they have access to the data in order to review it while like the shipments under review, so they don't have to place a hold in order to make that validation. And I'm not really familiar with the lab test reports, but like, is that something that would typically be available is a URL to be able to access? That is my question for all of you that typically available or is there another means that we haven't considered. Okay, thank you. The test reports. So the test reports would be the result of a contract between the importer that's getting the test for the product and a test lab. Now, we are finding that some test lab organizations are willing to upload their test reports into required repositories for information. So if let's say FDA requires a test report, I hear, I do not know this for a fact, but I do hear that some test labs do load them up proactively for the importer and manage some of those data concerns. I think it's, it would be a inefficiency. I think in the overall review process to have a URL that goes directly out to the product. It's, you know, one less PDF that needs to be stored somewhere in DIS that needs to be manually as a form owned and ace. I think there's a lot of reasons why I think the URL would be so much more efficient. All right, I'm going to go to Kat. She has a few questions from our virtual attendees. If a manufacturer and a retailer direct import shipments import the same item. Can the PGA message set E filed by the manufacturer be utilized for both manufacturer and retailer importer. I'm under, I just want to make sure I understand the question. I think it's similar to what's been asked before. Can 2 different importers rely on the same data. And the answer is yes, as long as you're following the requirements and 16 CFR part 1109. Read that regulation and it tells you what you have to do to rely on another party's testing. Or another party's testing and certification. We always anticipated that people like importers who are required to certify. They're importing lots of stuff from lots of different manufacturers. They may not know all of the manufacturing information. They may not have done the testing themselves. So we wanted to provide a way for that to happen. So we did and we put some requirements. You can do it. You just need to follow the rule. And part of that is do care and it'll explain in the rule what that do care is. So each importer has to certify separately. The information might be the same, except for who's importing it. But each importer saying, yeah, I relied on this testing. I did my do care, right? So I'm certifying it. I'm content that they actually did test this correctly. So you need to have access to the test records, right? You can't issue a certification if you have no idea whether it was actually tested. You have to know that testing exists. You have to have asked a couple of good questions and satisfy yourself that this is an accurate certificate and then you may rely on it. You can issue your own certificate based on that information. And if I could just add, and I think that's the key, it's the issuing of the certificate, right? Because when an entry is filed, you know, a product is going to be tied to a line. That product that's tied to that line needs to be able to map back to the registry, right? Which is going to be data that's either inputted by the importer on behalf of the importer. So you've got to have that connection. So you've got to have all of that information available to be able to map back to that product when the entries filed. I'll go back to Kat for a question. Would an image of the product on the CPC cover the model name, color, description and style request? Yeah, I'm not quite sure if we have the space for the images as part of the message. But you can't search data off of pictures. So we can't key off of it and we can't do systematic research in terms of trend work. Kelly Nasredi and I with Bureau Veritas as a test lab here. So we were talking a lot earlier about identifying test labs based on an ID associated with them. Would that be citation specific? You know, like if one citation was tested at X lab, another citation tested at Y lab. Would that be citation specific or certificate specific? So I think you're asking whether you have multiple labs listed on one certificate. Correct. Yes, we will allow for that. So if you do have that means where you have one lap, one citation, one lab, another citation, a different lab. We'll built in features. And then as testing is updated, say on, on repeat products and things like that, would there be an ability to update those locations, update those IDs, or would that be a new message that No, there'll be means in the product registry to update that information. We'll discuss this later, but we want to create some form of versioning control. We're able to create new versions of certificate for that reason, when you have an update, such as a new citation or a date, for example. Okay, great. Thank you. You have been waiting. Hi, Diana guilt with FedEx trade networks. I had a couple of questions. By first is, is the expectation on the broker. When we receive a product registry ID on the paperwork that we are going to go and look at that ID and confirm that it matches the item that's on the invoice for every shipment. Or are we allowed to be comfortable with trusting the party who's putting that information on the paperwork. Go ahead, Mary. I think that's something we'll have to consider because you are acting as an agent of the importer. So what does your that something maybe the rulemaking should consider. So we'll collect your thoughts and information. I'm interested to hear it sounds like you probably don't want to do that based on the way you ask the question. So that's something we can consider during the beta pilot and during the rulemaking on how that should occur. Okay. My second comment, more of a suggestion. They mentioned providing the URL for the lab test. So I myself processed entries for 10 years and I can say lab paperwork. Very rarely in my opinion would be available online. The vast majority of the time they're sending in a copy of the actual lab paperwork that they've received. I'm not at all against the possibility of providing a URL. I think that's a fantastic idea. But a lot of companies that are testing their own products may not have the ability or the interest or the knowledge to put that information online. And they would probably prefer to send in a copy with their shipment documents and then we would upload through DIS or however that's handled. Just a suggestion. All right. Thank you for that. A comment on filing from FTZs. The 3461 is an estimate or projection of what could ship from a zone in the coming week. The 3461 is reported, summed up at the HTS country of origin and manufacturer ID number, not at the product level. Therefore, for every line on an FTZ 3461, you could have many different products. If each product requires a unique registry number, it would be impossible to report on the 3461 because ACE has a line limit of 999 lines. Product level would result in many thousands of lines. I think I misspoke earlier when I said form 3461. I'm not well versed with FTZs, but the idea here is if you, the certificate or the e filing requirement would occur once that product leaves the FTZ and enters commerce. So not when it's, so that's a 75 01 I believe. Okay, I see a nodding head in the back. So I misspoke. So it's just keep in mind it's when it's exiting FTZ. And then there's 1 more. Will the product registry be accessible to customs brokers based on importer, or will it be general access? In other words, will an importer be able to control who has access to their products in the product registry, ie a manufacturer or customs broker and control what access they have. So the only idea that I have, that's something we still have to discuss in more detail and figure out. That's actually a good comment for our next session when we discuss the specific product registry features. Okay, Hector, are you ready back there? Hello, this is funny again. Can you guys hear me better? Arthur, could you confirm? Okay, wonderful. Thank you guys. Again, my name is funny flores faster. I'm with the car systems group. And my question is related to the message set checkbox field, which is the 1 of the added new field. Where is supposed to attest that the individual certifying compliant is certifying that they have the product and the certificate for it. My concern is that most of the time the PGM as I said, it transmitted by the, by the broker. While the certificate from what I'm hearing is mostly done by the importer. So when we are doing this checkbox and is being sent by the broker, who is really attesting the broker or the importer. The testing is the, is the importer. So if the person has used the product registry, the checkbox is in the product registry. So they will be whoever's uploading that information is attesting right on behalf of the importer. So as the broker, if you're using just a reference, you're just typing in the reference number. So I don't think you ever get to the checkbox if you're doing the full PGA message that then you're typing in all the information including the checkbox. And then you're an agent of the importer. So it's the importer is making that attestation. Okay. So, so I guess I just want to make sure that when the message set is prepared, there is a clear statement that clarifies that point that even though the broker is doing the filing really who is checking the box is the importer. Right. Yeah, that should be clear on the software. And also, I believe we do have an NPR sitting out there from 2013 that talks about this stuff. We're going to be doing an SNPR supplemental NPR next year. So it does talk about this to who's on the hook or the attestation and it is right now the importer of record. Thank you. Okay. Go to the back row. You're in the hearing room. Hi. Is the registry going to be able to accommodate duplicate entries with the same ID number? Like if two retailers are importing same product has the same UPC, but maybe different batches, clearly different entries. If it's the importer managing the ID numbers and creating the ID numbers rather than CPSC, is it going to accommodate for duplicates? So the idea here with the registry is that any filer, the importer in this case will have an account. So we have that additional verification information that's the importer and the ID. And so we haven't resolved that issue entirely, but the thought process is that when they, when that's filed, we're able to also match on the importer, not just the ID. Right. Because we're looking at two pieces of information. We are. Okay. So your primary key basically is going to be like the importer number plus the product ID. Yeah. And so those will have to be unique. You can't have the same product ID with the same importer. Yeah. So if the product, yeah, so the importer has is using the same ID number, that'll be an issue because then we don't know how to match it out. Or it'll be, or it'll be the importer and the reference number based off of the fact that you're saying that there's a lot of product that doesn't have product IDs. And so if you don't have a product, you know, like a handmade something coming from the Andes in those types of situations where there isn't an identifier, there'll be the reference number that you're using for, you know, a test station and certification. That's going to be on the registry. That would be the identifier. And then the importer would be the one who's managing. And then that could also track. So then you're going to have that probable double primary key match that we're talking about there. This is all, you know, part of development that we're going to have to work out. Sure. And that brings me then to my next question. I'm assuming that you're going to have some sort of validations in place that you can only transmit. Product registry ID that belongs to that importer. Yes. Okay. So, okay. But that's a good idea to bring up during the development. I think as we, as we review development, part of the problem is going to end up being that there's going to be certification that an importer is going to manage that's going to be. There's a lot of importers of the same product models that are going to end up occurring. And so there's going to be a lot of repeat data that's going to have different reference IDs. And so that managed information is going to be tracked by the importer. We're going to have to make sure that those databases are working properly when we match it up with CBP. Right. So this, this complexity is something that we're going to have to work out and it's going to get worked out with our nine, nine practice people. So please volunteer and become one of those to help us make sure we get this right. I already have. Okay. So then that brings me to the next question. So you talked about product, product registry updates, being able to update a product registry. Is that going to then generate like a new identification number, like a dot one or something so that you can then identify which. So that's, I'll address that in the next session. But okay, fine. And then one more question when we talked about multiple labs and certain labs certifying to certain certification rules. Is there going to be like a linking there? Are you just going to report, you know, three rules and two labs? Or are you going to report lab one, rule one, lab two, rule two and rule three? Yeah, it would be. They'll have to be there. That would be like, that's what we did in alpha pilot. You first actually identified the lab, the citations below, and then you're able to create a new line next lab, the citations and so on. Okay. And then I just have one more question. Who actually completes these certificates? Is it the importer that's doing the certificate? The manufacturer? Well, it could the manufacturer. The guy that gets it down the road. So the importer still has the responsibility of certifying and typically they will create it. But we've seen in the past where a manufacturer or laboratory would also would create the certificate or for the most part create the majority of the certificate. But then the importer, so certifying compliance has to finalize that certificate. Okay. Is there any indication on the certificate that it was created by one party and certified by another or not necessarily? Not necessarily. It's just the importer is responsible for the accuracy of the certificate. We've seen like, there's no actual template to the certificates. So we've seen different headers. So we could identify sometimes a lab has created it, but it's still the onus on the importer. Okay. Thank you. Okay. Hector. Go ahead. Yes, we have another participant. Katie Tangman, please. Hello, can you hear me? Yes. Okay, great. Hi, thank you. I'm Katie Tangman with Columbia sportswear company. First of all, thank you for hosting this workshop. I've always admired how. The amount of study and thought that CPSC has put into these programs. So thank you for that. I'm also a board member of the national association of foreign trade zones. So when you're, when you're, when you saw that last comment about foreign trade zones. I'm also representing that program here. So the other comment that I would make is that the challenge with reporting this on a 70 501. Is the zone 70501 occurs after all of the goods have shipped from the zone into the commerce of the United States. So those goods are then no longer available for inspection. The other issue again, it relates to that issue that we have on the 34 61 is also on a foreign trade zone. 70501. The goods are summed at the HTS and country of origin level on that 70501 not at the product level. Every line on that entry could contain anywhere from 1 to a couple hundred different products. And again, we're limited by the ace limitation of 999 lines on both the 34 61 and the 70501. So, so there are some challenges unique to foreign trade zones. I would actually highly recommend and I think I put a follow on comment there in the Q and a that's that the team meet with the executive committee of the foreign national association of foreign trade zones. To better understand or more than likely will be a subcommittee that will be speaking on this topic. To really better understand the nuance and the complexity associated with foreign trade zones. And to find out if there's a better way. You know, I know that foreign trade zones ended up being excluded from the alpha pilot because of these complexities. I suspect that they will be excluded from the beta pilot because of these complexities, but I, you know, obviously. When you want to make that final rule making and have the entire trade be participating in this. There's going to have to be something different. For foreign trade zones. So. So, Katie, we would love to have your participation or any of these participation in the beta pilot because this is an issue we need to resolve before we make the filing permanent. So, although it was excluded in alpha, we won't exclude foreign trade zones in the beta. And also, if I could speak, this is John will share it just real quickly. The information that comes out of the FTZ's we can actually act upon by knowing that the product is then present in the FTZ and then be able to follow up in the FTZ as necessary. We do have examination capabilities and FTZ's. We've had that recently. I understand that, but in that case, then you're going to follow up on product models that sit in the FTZ. And that remain because there's an expectation that the weekly delivery isn't necessarily exporting everything. So that's always, and then again, we always have domestic capability to get to product. So in either instance, we can follow up based off of the information that comes off of a 7501 is necessary. So that's number one. Number two, a lot of our targeting ends up coming off of entry, the 3461. So as the information matches up off the 7501 and trying to get it down to the product model as you stated is going to be a challenge. So as Arthur stated, we really would love to have you as a participant to help us work through these types of nuances because we definitely are aware of a sector of commerce that we need to be able to get to in the FTZ. Hi, Katie. This is Jim jaholsky question for you. And I think this is a. I think a question that would sort of apply to a number of areas that we may touch on today, but for for FTC FTZ. Admission or. Entry out of an FTZ. To what extent do you know now how PGA message that data is attached for other agencies like FDA or. Anyone else because, you know, we're, you know, to the extent that we can, we're not trying to reinvent the wheel here. We'd like to be able to leverage if if there is a process in place where other agencies are. Receiving PGA message that data, you know, we'd like to be able to leverage that to the to the best we can. So I don't know if you can can share anything about how PGA data is is provided for other agencies. Yeah, and I my my knowledge is somewhat limited because. There are such a broad group of PGA's and of course, a large number of, you know, different commodities that. Come out of foreign trade zones and of course, apparel and footwear. Fish and wildlife ended up with just maintaining their external system. For registering importations because it was not feasible for them. To utilize the, you know, the 734 61 or the 7501 an ace. EPA as well. Just based on the point in time at which they need to actually. Target and capture goods. So, some some PJ's have actually chosen to not participate. In this model because of those complexities and I think there are certainly some. That are participating, but, you know, they're, they're. You know, I think we would have to get some other people on to a, you know, a call to sort of help help you better understand how that's being used in. In the foreign trade zone realm and ace. All right. Thank you, Katie. You have response. Okay, so I'm going to. In person audience. Thanks, Katie. I just wanted to let you know that for a fist or a fist Lacey. There is a the ability. There's a registry on their site called logs. And you file your data there. And you then in the zone. Information on the, I think it's the 751 you disclaim. Because and the disclaimer is that's filed in a different means. It's not in the message set. So that might be a model that you might want to look at. FDA has a slightly different model. They have what's called Weff. Where you have to seek their approval. Yeah, thank you. That's a good idea. Okay. I have a quick question regarding to the point three. So right now I understand that the product description is one data field as a free text field. Is that correct? Yes. So do you have plans to break it into more modular field like one field for model name one field for color one through for description. Well, that's something we would discuss as we develop the beta pilots. That's something we would discuss with the participants. What is the best approach to that? Whether a free text field is best or break it up and keep those all those fields optional. So you fill in which field you think is as suited to your needs. Okay. Thank you. Any more questions? Okay. I at this point, I will end this morning session. We'll break for lunch and resume at 1pm. All right, welcome back everybody. We're going to continue on with the second session discussing the product registry features. Andrea, I want to take it away. There we go. All right. Thanks to everyone for coming back. I know it's lunch is a very time to say. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. I'm Andrea. According to this day 6. How we're going to access the product registry, that's something that we are going to build in house. It will be a software solution designed and developed within CPSC alongside our e-filing program or an e-filing infrastructure more broadly. As we've mentioned before, the importers who use the product registry will create their own unique profile. Which should help with discerning two importers using similar products or even the same products with the same certificates. Brokers and labs can be granted third party access by the importer. This is a question that I've gotten as I've been doing presentations alongside Arthur. So we will not be just putting all of the onus on the importer for this. We will be able to open this up to brokers and labs, but it will have to be managed through the importer. You won't be able to do things independent of the importer for information control and security purposes and all of that important stuff. So we're going to have the option for batch uploads, which is going to be very nice as you think about your data entry requirements. We will have the ability to just load a single spreadsheet in and load up all of your certificate data that way. The way this would work, you would load and of course take this with a grain of salt because this is all sort of in development. We don't know exactly how it's going to work, but this is our idea. The product registry will be able to ingest a spreadsheet of a bunch of different certificate data for different products. And then you will be able to get your product, your product registry ID out from the spreadsheet that you put in. We're hoping to build that out more as we develop this system. So if you want to take part in some of that testing, you should sign up for the pilot. As we've mentioned before, one product per e-filing certificate. That's very important for data quality concerns and the fact that we are using this for targeting purposes. And we are going to allow multiple models, like we mentioned before, as long as all of the certificate information remains the same for each of those models. It's really important, and I can't stress this enough with the product registry, that the information has to be current. It has to be the same if you are using it for the same product. So if your certificate expires, a year after you put it into the product registry, you're going to have to re-upload that information. So keep that in mind. We want to make sure that everything is as accurate as possible, and this isn't just a set it and forget it type of system. So we've got versioning and copying controls, hopefully built into the system as well. The versioning would allow filers to upload certificates and update your certificates and keep the product registry ID the same. So this is what I'm talking about. You update your certificates as they need to be updated as the information expires and then is recertified. You can keep your product registry ID the same, which is great for the brokers of the room because you're not going to have to sort through a bunch of different product registry IDs to try to file on behalf of your importers. We also allow copying, which will allow you to copy the existing certificate data to a new certificate with a new product registry ID. This is really useful if you've got similar but not quite the same products. So maybe they have the same lab information. Maybe they have the same manufacturer or something like that. You can keep all of that information and more easily conduct the data entry. And that is the general overview and I will hand it over to Arthur for some discussion on this. I know it will be pretty robust with all the interest. Right. Well, thank you, Andrea and let me go through the questions we want feedback on. So first of all, would you as an importer being favor of third party access for brokers and labs and tangential to that should other parties have third party access with regards to the batch upload features that's something that you would use. What would your requirements be for batch uploads and lastly, would versioning and copying controls be useful for you to have any feedback on that. So I will open the floor to questioning for approximately the next half hour if we need all that time. All right, Michelle. So would you envision with the batch upload process when it takes in the spreadsheet then then it would lack of a better word regurgitate. One product ID that then you would use for everything that was encompassed in that spreadsheet or would it be smart enough to sort of parse it out into the unique circumstances that would require an individual product ID. So the thought is that in your spreadsheet, each line is a separate certificate. So like the first column would be that ID and the remaining columns be the additional information required in the registry. That we were going for. Okay, well that that brings up another question. So then you asked like what would the requirements be. Like, there must be a finite number of rules, right that things could be because I'm trying to think of how that would look right with you could have multiple rule and manufacturer combinations that spreadsheet could get pretty wide but I mean probably not unmanageable. But that would be different than say like a multiple record or certificate type of layout, right, because you could have multiple manufacturers so if I only had one column for manufacturer. Yeah, you know, and like you mean also for the lab. Yeah, right the lab. Yeah. And then we could work on as part of the preparation for the beta pilot, I'm not that savvy with it so I don't know what the best approach would be, but that would be something we would like input on. Okay, and then when you talk about third party access I'm assuming that would be like read only access for a broker or, I mean a lab might want. It might be advantageous to have a lab be able to actually update records. Right. I thought there is that even a broker or a lab could enter the data or update the information on behalf the importer. But the importer was still be responsible for that data. Okay understood. Thank you back grow. Good afternoon Sylvia with class twin. Assuming multiple parties can work in the module. Will there be an audit trail who change what. I would imagine so that's something we could develop as part of the registry. Thank you. One of the questions was the alpha pilot you previously completed. Was this based on air and ocean shipments. And how would he filing for work for 16 CFR 1640. Hi. I don't. First question. I'm not quite sure. I'm not quite sure. You answered. Yeah, could you answer that John. I'm pretty sure for the first question that we ran the alpha on ocean air and truck environments. And that was it. So to the second question of the 1640. Yeah, I'm not. I don't know my 16, I think, Mary, are you looking that up. So for the upholstered furniture, right? Okay. That's a new. It was a statute and we just codified the statute. The statute actually accepts. Uh, upholstered furniture from certification requirements. So we're going to have to think about that when it requires an on product certification. So that might be one where we have to do special programs or something we'll have to think about that one because. It's not by statute. It is not subject to the certification requirements. I don't know of anything else by statute that's like that. Section 14 a of the CPSA requires all regulated products to be tested and certified. So here Congress has done their own thing. So we'll have to think about how we want to enforce that particular rule. But it won't be through e filing. Right. And right now the HTS codes with respect to upholstered furniture have not been identified. Right. So we'll, we'll think about that one, whether it's. You know, there are a couple of options. Do a separate program. We could do a disclaim. We'll have to think about that one. Then someone else asked, where is the CPSC supplemental guide? Oh, the IG is. In regards to the cat hair. I, yeah, maybe, yeah, you can answer that alpha for the CPSC. The IG, the guide should be out on CBP.gov. I've not validated that it remains. I don't think they have they taken it down. They may have pulled it down. Otherwise, did we put it on our website? It's not on our website, but we have a copy of it. Do we want to put it up on e filing? Just to say, here's archive documents from the previous iteration so people can watch what we're doing. Yeah, we could do that. Okay, so there's a thought to try to get some of the alpha documents up on the website that people can refer to generally and say that these are old documents that we'll be working from. So we may take that back. Okay. Okay. Certain US states use I see to portal for CHCC reporting, which my chat just went down, which allows manufacturers to do a batch upload has the CPSC looked into the features I see to offers. I haven't heard of that. Thank you for that comment and we'll look into it. And then we have another question as a follow up will multiple users be able to access the registry for an importer simultaneously, including that audit trail. And could they access the same product simultaneously. I don't quite know how. The answer to that because that would depend on I think on our T developers, we could take that question back to them as we build out the product registry and see but I don't know. I'd have a follow up question back should it should it allow more than one person what's the benefit to that would anybody ever use it. More than 1% at the same time. AT capabilities to be able to do. Simultaneous editing and then if they save at the same time, you just have side by side versions that would then exist in the system. So we'll have to take a look obviously what Arthur just said is, you know, that's going to be part of the development considerations. Is, you know, multiple people getting in and editing at the same time and having those type of controls. Do we lock out an account if it's 1 person at a time type type controls in this type of situation. That's the kind of questions we'll have to ask. Yeah, and those are the questions we want to hear during the development. So another reason to participate, especially in the it advisement is we don't have I personally don't have this it experience. We have it developers who have more. Of course, have the experience and they will be asking the participants specific details that were specific details and we want kind of. We'll be asking detailed questions and also on detailed questions back from you. Go ahead. Yeah, she's coming. Thank you. Something to consider with the version history. If there's not a way to actually differentiate versions of the product ID. So for instance, let's just say the number is 1, 2, 3, 4. And the importer goes in they update something simple like the last date of lab testing for a new batch of products. Everything else has stayed the same. We've done a new test. This was the last day it was done. If that's not going to be 1, 2, 3, 4 a, as an example, when they ship product, their paperwork is only going to say that original version number still and it could become really difficult. If CPSC is auditing a file to know which version of that ID goes with a shipment, because just because you know lab testing was done at a certain time, and then they do another set of lab testing that initial cluster of product hasn't necessarily all been imported. So they could still be like looking back on previous versions of testing. Yeah. And we want to build the registry in a way to allow for that. My thought is to have suffix like a B or just like dash 1 dash 2. And when you file in the message that you would put the whole ID with that suffix. I think that's a great idea. Okay. But I'm open to different ideas to make it easier. For the message. If there's no other questions right now, I wanted to explore this 1st topic a little bit on. 3rd party. Access to the registry on behalf of importers and. And sort of ask generally importers. Is that something that you're looking for from our perspective what we're trying to build is something. That can be the least burdensome. As possible. I think it's still allow us to get the information and be able to process it and use it for targeting, but for the trade to make it. Set it up in a way where it is the least onerous, you know, that that we can. And so, I mean, I've had some conversations with with brokers and test labs and it sounds like, you know, a lot of brokers and test labs have this information already. So, you know, just from the broker test lab perspective, are you interested in doing this work on behalf of of importers? And I guess importers. Are you interested in having brokers and test labs do this work for you? Because we want to be able to set it up in a way that works for for everyone. So just any input that anyone has on that. I think I'm the only lab in the room. So on behalf of labs, yes, we are interested. We do have that confirming. I would think as from a broker's perspective, it's the kind of a double edged sword for integrity of data. You'd probably want one person responsible for the data. If they use a multiple brokers, you might have multiple versions of data. At the same time, we'd like to maintain our product database and order our product database. So it's kind of a double edged sword in my opinion. Yeah. And, you know, from a broker's perspective also, I would say that we want our customers to be responsible for that data. Right. We don't want to be responsible for that data. And I mean, you know, could we possibly offer it as a value added service? You know, possibly if the importers say that that's what they want. But I really think from our perspective, it would be preferable that the importers that the owners remain on them to, you know, verify that information. I do recognize that as part of the process, the audit trail is going to be robust. You're going to have a last update user type situation. We're going to have multiple user and sub user type account situations where you'll have one person who owns the information, but other people potentially updating. So there should be some type of sophisticated account capability where you can have single simple, you could have one owner with multiple users that can update and so on. And our design is going to need to be able to be robust enough to provide a full audit trail and the kind of security that's going to let you know as an account owner who's updated what and when. And so that will be a requirement. Also recognize that we see this as, you know, some of the higher sensitivity information that we would have. So we would have this be secure information in a tight, you know, secure environment. Yeah, and that audit trail would be necessary on a field by field basis, right? Because you would need to know who updated exactly what when. Right. And so probably what would end up happening in this would be part of the IT review and how this would be maintained. It would be, you'd have a recordation of. Yeah, you're going to have the 1, 2, 3, 4, half an alpha for the update of a lab. But if somebody else then comes in and does an update, this would be version 2 of the 1, 2, 3, 4 alpha or a. And then, you know, if there's a change, then it's 1, 2, 3, 4, B. And then somebody else does an update that could be a B2. And each of those would have the latest person who did those updates with the capability to track edit changes when and where that would be the kind of control. I think we would be looking for. And to add to that certificate typically are required to be recertified once a year. So the thought is, you know, the importer could go and put the certificate information or the broker could do it on the behalf of the importer, the lab on behalf. So, as John's example, I don't expect you're going to have multiple versions occurring so often, but at the minimum once a year. But that's as we have copy control too. So if you have a similar product with a very similar certificate, you could copy that, but that's a different ID number. And this is going to be kind of a weird request and this is something that we could possibly as part of version version and control and thinking to what Arthur is stating. Would it be useful to provide messaging feedback when a certificate is dead when it's gone past the 1 year and we just we kick it back to you and you say. You're the account owner. You're the you're the master level on this. You're 1 years up. Re up this or this product is going to fail the certificate load process. You'd appreciate that. Mary wants to speak wrong with notification, but depending on how they're set up. Some manufacturers or importers can earn a 2 year cycle and some are even a 3 if they have their own firewalled lab that's been approved. So. It depends on how they're set up. Most people are 1 year. But not all we could prop we could probably develop an account type situation where we got 1 and we have 1, 2 and 3. And that would your capability could also just be more of a reminder for the importers because. In theory, you could still bring in products under that certificate if if it's stored overseas and it was and you followed the procedures manufactured 2 years ago, test it 2 years ago, you could still bring in that product under that certificate. You're not required to have that certificate done in the most recent year, but if it was something manufactured recently needs to be updated. But if the certificate failed because it wasn't updated. But it was manufactured and tracked to a dead certificate. It could fail potentially batch 2 or a 2nd bucket check, whatever it's called. Meaning that you got all the information in we're able to read it. So it's fine there. But then on validation and review. You have to go and update your certificate or this product has to sit until you know that could be a remediate remediable. Violation per se and not violation. I guess that's not quite the term, but and yeah, an edit check that needs to be done. And if you don't do it. Then you don't have an updated certificate. Because like certificate period is not a data element. Yeah, right. So what what hinges on the eligibility of the certificate when you say 1 year, is it 1 year from the testing date? It's good for or like, where does that. Yes, I mean, it depends. There's a rule. It depends. So it's something in the beta pilot we can talk through. So it sounds like it's something people would like to use, but how exactly it functions is something we can talk through so that we're not. Holding up legitimate trade, but it's a nice notice for people to double check. A combination of like the HTS code. What was filed what you stated it was. And then from there, we would know it's 1 year, 2 year, 3 year. It's probably some type of crosswalk. So certain products are allowed. It's that's just for children's products. Okay. It's depending on the type of lab you have 1, 2, or 3 years. Okay. I don't want to get too much in the weeds here. It's really just something we can talk through. These are the kinds of issues that are going to come up and we'll need to iron out. It could be something in your profile because it's the type of lab you're using. It could be. We'll just have to see and it's really it's more complicated than this 1107 has this whole thing about labs. So. I don't think we need to go through that now, but we will have to get into these weeds. During the beta. Okay, sounds good. Thank you. There, so it would have a reporting feature as well where you could like run reports out of this. We could consider that as a possibility. I've been. I personally haven't considered that. I think that might be useful to offer something like that at a minimum. The owner needs to be able to drop the most current information out. And be able to say, this is where all my certificates are. There needs to be an export function that allows traceability and be able to say these are close to being old. We need to update and manage. And these are the kind of things that I think we need to go through in terms of the requirements that we're going to set. But reports coming out of the system is something that should be part of a requirement that we put in front of our, our contractors as well. So this, this type of reporting functionality, I think is a good ask. And if you are 1 of the 9, you can help us to identify what reports should be built 1st. Awesome. Thank you. I do want to go to the virtual attendees. Are there any questions or any comments in the chat? There was 1 question. Will there be an API to connect to the CPSC registry for feeding the data? Yeah, I think that would be in relation to the batch upload. I'm not quite sure how our team developers would create it, but we'll take that into consideration. This is a question regarding to the reminder about the, when the certificate is going to expire, we'll get an alert. Can you also make it so that it's like four weeks before expiration, we get a reminder? Okay. So then the fall details will work through. Okay. So then the follow up question to that is I am not sure if we got the clarification on the start date. So when you count the 1 year, do you count the manufacturing date or do you count the latest test report issue date? So let's say 1 product can have multiple tests required. So you just count the latest test report issue dates or do you count the manufacturing date? So I know we said, or I said in my presentation that it would be the last lab test dates, these different labs. So, Mary, would that be 1 year from that date then? We're going to have to get into these weeds because there are some products that have component parts and the component parts are all tested separately. But then, for example, toys, there are certain tests in F 963 that you have to do the whole product once it's assembled. So, and you can imagine all the different products with different rules. So we're going to have to think about this. I hope not on a per rule basis, but I think toys is probably the most complicated. When you're talking about adult products or general certificates of conformity, usually just 1 rule. It's a mattress. We're going to test it for mattress my mobility. But once you get into toys, right, you've got lead and phthalates and small parts and the list goes on. So we will be able to think through these issues and come up with our algorithms are going to have to be able to search on these things. So we are going to have to standardize what is the date we're talking about. And we're talking about a certificate for the entire product. So last test date does seem to make the most sense at the moment, but we need to think it through more specifically. Yeah, I agree. And I think with all the complexities that Mary's just mentioned, I would envision that we would probably be sending something that says, you know, something to the effect of, you know, you want to look at this certificate. It may be close to expiration, right? Because there's a lot of different factors in play, not making a definitive statement that it has expired. I just wanted to make one comment about the batch uploads and I mean, this is going to be a significant improvement in improvement over what we did in the alpha. So for some of you that were part of the alpha pilot or followed that may know that every entry that was put into the registry for the alpha pilot was hand entered. There was no batch load used. So, you know, moving into the beta and then and then with final implementation, the batch upload is going to be really, really, really important to make sure we get that right. So, you know, as John and Arthur and others have stated, you know, that initial nine group that's going to help us with it development really that's another critical part of this making sure that we get the batch load, the building of the batch load correct. Anything we do have a few more minutes left in the session. So any, we have a more question there. Hi, you may address this later on in the presentation, but do you have any vision on how these testers will communicate how the discussions will be organized for these down to these detail levels? Is it going to be surveys? Are we going to get into small groups? Any thoughts? My personal thoughts would to do small groups and working sessions to really get to the detail. When it comes to the pilot itself, I would like to do a survey, maybe periodically and also that's also one of the reasons why I was asking for your IO number and the products you would be importing so we could keep track of that and and see the numbers of entry lines that are coming in. So that's, I haven't quite gotten to that point, but we still have time and I saw something as an importer, we would be in favor of having the labs access to have have the labs have access to upload data to the registry. They are the experts in the Serena. They have the data and do all the testing to it would make sense to give them access. Okay, thank you for that comment. There are no more comments or questions for this session we can proceed. Next session. Okay, we're going to talk about HTS codes, disclaims and exemptions. There are approximately 300 HTS codes that will be covered by the beta pilot for anyone that doesn't know what an HTS code. It's the harmonized tariff schedule. And it's, it's basically the classification system used by CBP to determine duties and taxes paid on imports. These HTS codes primarily include products that require certificate of compliance. CPSC staff will publish a list of HTS codes prior to the beta pilot and these codes will be flagged at the time of entry filing. The CPSC commission approved of including these approximately 300 HTS codes in the beta pilot. The list of HTS codes is almost the same codes that we actively target in RAM currently. We won't be flagging 15 J products as part of e filing as done in the alpha pilot because these products do not require a certificate. Disclaims. Certain products that will be flagged at entry, but do not require a certificate in this scenario, a disclaimer would be required. And these would include products outside of CPSC's jurisdiction. So an example of that would be like medical products that are similar to general use products such as hospital mattresses. Products within our jurisdiction, but that are not regulated such as collectible toys that are not for children, adult backpacks, 15 J products and defects. And then products within CPSC's jurisdiction and regulated, but no certificate is required per commission enforcement policy. So something like that would be small rugs. And then we have exemptions and these are for products that are exempt from a lab testing requirement. The filer would list no lab testing required in the laboratory field of the PGA message set or the product registry. The filer would also cite the CPSC statute providing for the exemption. So an example would be plain surface fabrics that weigh more than 2.6 ounces per square yard that are exempt from testing. Citation codes for exemptions will be included in the list of CPSC statutes referencing earlier to maintain standardization. And some questions that we're considering. Should CPSC consider other disclaim sets and how often do you have a lab testing exemption for your products? And I'm going to let Arthur take over all the questions. Yeah. Rather quick session. But I see we're going to have a few questions. What do you mean by consider other disclaim sets as opposed to just regular disclaim through the PG set? In addition to the 3 we've listed out here. Do you think can you consider another scenario? Other product scenarios that would require it. Yeah, that's what you're asking. I thought you're looking at it from the PG message set. No, I have 1 idea for the FTZ zones. Yeah. Right. I was looking at more from the IT side on the. There are different methods that are just claims as opposed to. Yeah, maybe that's where the upholstered furniture falls to. I'm not sure, but that's 1 idea. Things like that. Other reasons you can think of to disclaim besides the 3 that we. Just mentioned in in rule. Testing exemptions like if the, if your rule was just for labeling, we don't require. A lab test of labeling. You can self certify that your label is correct. For example. Right. Are these disclaims going to follow the same kind of. Process that all the other PGA disclaim. Yeah, so the disclaim process we're working within the standard PG message set for disclaim the architecture there. I do not remember if they've got. Distinct flavor codes for each of the types of disclaim. I don't remember that, but there is a structural layout. We're going to adhere to that. We don't want to change anything that CBP's already built in terms of these types of processes. But I don't think they have structured the different types of disclaims that there are. I think that's within the data, not as, you know, I don't think they standardized. We would have to work within CBP's guidance on conterres in the IG. I know they already have kind of a set list of disclaims. So I have, when we created these 3 bullet points here. It may not exactly appear like this in the disclaims. It depends on how it works with the PG message sets. Good. To identify a disclaim or products that were domesticated, for example, so they were able to adjust a disclaim. Okay, so the comment was that fish and wildlife was able to adjust this claim. So we'll take that in consideration. I can you go to the next slide? Sorry, I have 1 more question. The citing this statute. Is that going to be a drop down menu as choice as well? Yeah. So the idea is this will be very similar to the lab field in the citation fields. It's just instead of selecting a lab, it would just be an idea for no lab testing. And then you have the option to select the exemptions, which we would. So essentially when we provide that list of labs and citations. We'll just treat this as a lab and a citation. Yeah, otherwise that'd be a lot of typing. Yeah. Of a related question. So for other agencies, how often are you all using intended use codes in the appendix? I forget a lot. So we've established 5 or 6 different types of intended use codes that we could potentially be using in these types of situations. For example, a product that was not going to be put up for retail sale, but instead the product was going to be used for manufacturing that's not yet been developed yet or whatever. We have a whole bunch of intended use codes that we could actually review as part of this process as well that could be included as part of potentially filing under underneath this. And maybe we could adjust that as part of this process. So is that something that you would then be adding to the certificate is an additional. That element. No, the intended use code would be something that would be able to be filed in terms of the message layout. So I know there's a location in the PG message for intended use. It's a 6 or 8 and we could possibly activate that to say this was packaged for retail sale or this is not intended for retail sale. This is intended for industrial use only. We have a set that we did about 4 or 5 years ago and we can go back and look at those to potentially add to this disclaim and information layout. Thinking from the broker perspective like where would we obtain that information right if it's not part of the certificate. We don't necessarily know what you should get that from the importer. You just would you would have to you'd have to ask that as an additional element. Okay, just to orient us. You're talking about we're talking about disclaims reasons why you don't have a certificate right. So you're saying like it's not an 01 consumption. No, it would be an 01 consumption. But because this is a it's a toy that's not yet ready for packaging. It's not finished product. It's not finished product. We're not done with it yet. We haven't packaged it and put it in a final container. There's there's a bunch of these types of codes that we worked through that I just as we're talking this came up. We can review these things useful to talk through in the beta. Yes, exactly. Only finished products require certificates. But sometimes it's hard to know whether it's a finished product because if you go to a craft store, there's a bunch of doll heads you can buy right and they're sold as finished products. But you could also import that same doll head intending to integrate it with another product and you're not intending it for sale as is. So it does have to be compliant at the doll head, but it may not need to be certified until it's finished with the whole product. So these kinds of issues could come up. So these intended use capabilities that differentiation we could utilize that and make it so that it ends up informing the overall process a lot more. And that would be an example using this claim because if the doll head is not considered finished product, then I would say it's the second option here, right? Mary, it would be fiction. Yeah, yeah. So typically for I'm sorry. So to jump off what Mary said, we have to consider that as possibly an addition of this claim. So I can't think of any other agencies at the top of my head. Usually a disclaim is just that it's a disclaim and it does not contain any additional data elements, right? Like an intended use code. Normally, you know, disclaim is again just that. So you might want to think about maybe like a limited data set type of environment for things that don't require the full message set, but yet are not quite to the level of a disclaim where you're not looking for any information. Yeah, I hear you. What we can do for disclaims as well is that the reason for disclaim is actually a large text field that can be populated as part of the message set as well. I do remember seeing that as we did an initial build out back in 2016. So that I believe there's an open text area where you can actually do some type of and we could possibly as part of the application and data transfer. Maybe we can drop some data in there that helps to inform this why so that we can validate that against what you're what you're trying to do. Because I mean we're going to obviously have to check some of these disclaims because people are going to if they get the option to disclaim they're going to they're going to do it. I'm just let's just be honest. I will CBP be part of the working groups because CBP has a lot of this information and can really help facilitate some of these discussions as to what their ace can accept right. Yes, we are working with their development team the schedule you saw earlier where I detailed the IT development schedule that had that schedule I developed with the CBP development team so they're they are very well aware and we'll be working with us closely. Yeah, we were meeting with Fish and Wildlife. It was a subcommittee of COAC. We also had Fish and Wildlife in the room but we had speak in the room to an office trade. So if you'd find that useful. Thank you. Kat, are there any comments from the virtual attendees? Okay. During the pilot when moving to the production environment will HTS be flagged as may require CPSC versus CPSC declaration is required. I haven't gotten to that detail and it may depend on where the participants are with if they're if they feel they're capable of providing that data or if they feel confident for certain products and not for every product. So that's something we could still discuss and resolve this part of development stage. I think we'll have to as part of this look at each of the HTS codes and determine whether we're confident that everything that would be imported under a particular code would require a certificate and I can think of some of the toy codes that we're pretty confident without possibly some very limited circumstances. But as you all know, there are a lot of very broad HTS codes that we're not going to be able to make that statement. And so I think it's going to it's going to be more on the may require certification rather than does require certification. This kind of relates. I've been asked by importers brokers and want to participate but may have mentioned to me that maybe not for every product consumer product they have. But maybe for a subset and we're happy to just include that subset as part of the beta pilot and hopefully expand to the full set of consumer products you may import. So that's like tangentially related to that question about HTS flagging. Cat, are there any more questions? Having some issues with seeing all the questions. So just know that I'm not ignoring you. It's just we're having some problems. I have there's apparently some questions. I did not see one question was how will samples for procurement of sales be handled. Well, in order to, you know, under the statute section 14 a requires it to be an entry for consumption or warehousing or distribution and commerce. So if you're not importing it for consumption or warehousing or distribution and commerce, then the certificate requirement doesn't apply. So. Two possible notes on that. I believe. There is an entry type that is specific to samples. If I'm not mistaken. I might be wrong there. I know there's an intended use code and we can do an intended use code that actually says disclaim because this is a sample. We're evaluating. We're not going to sell it. So I believe in, in either situation, we can set up a situation where we're getting out of the way of those that are going to be just samples. You're not, you're not selling. But we'll also watch those in terms of value and volume because if you're bringing in 10,000, I'm sorry. That's not a sample. There was one more question regarding, will CPSC publish a list of products or examples of products that fall within the three disclaim sets? We could do that. I, we, I know Kat, you provided a few examples, but we could provide a more robust list of examples. But I think that's a great idea. Thank you. Any other questions from the audience? I will just say on this, we were expecting a more robust discussion on disclaims. We really felt that this would be an area that people would want to dig into. It may be that you all are comfortable with this process and how other agencies do it. And again, we don't want to reinvent the wheel. If there is a process out there that works and that we can model what we're doing to be in line with that, certainly from an IT development perspective, we're going to be working within CBP's structure. But I think in my mind, this is sort of good news that there's not, not more questions and more, more issues around this. So that's great. I think we're just confident that from what we've seen from the other agencies that CBP has laid the framework for a pretty robust disclaim process. And as long as you utilize all the options that they have available and don't just try to cram a square peg into the round hole, you know, or try to prevent disclaims or, you know, when they should be allowed, I think we're all going to be good. Okay, great. Yeah, I mean, I think as John alluded to, you know, we'll have to build in a check on the, on disclaims to make sure that the process is not being abused. But that's something we'll work into our risk, our risk modeling. We have a question in the back row. I just wanted to mention that I don't think any other PGA uses intended use codes on disclaims. But what we do see is something like NITSA for vehicles that are off road vehicles that are never meant to be on like actual government streets, but they have really limited data sets. So it's a specific category code and you put in a couple of, you know, pieces of information. So that might be the route that we can go for this one. Sorry. Kat, anything? See, follow up to a prior question, will sample flagging be limited to a census measure of products we bring? Samples on seasonal baseness and sometimes have 300 individual toy samples, for example. Well, the flagging will be on an HTS level. I don't quite understand that question. If I'm understanding the question properly, you're talking about you might be on a shipment bringing in 300 units for potential valuation for sale, being a wide variety of things that you might bring for seasonal type promotions or whatever. So in terms of when I made the comment, you know, if there's a thousand of them or 5,000 of them and you're disclaiming, we're going to, again, these aren't set into stone. So don't get too worried about disclaims at this point in time. If that is your concern in terms of product samples coming into the country, we do recognize product samples come in. We're not an expert on how they come in. We'll try to figure it out and work with you to figure out ways that make sense. One thing I did want to mention, if I'm not mistaken, we've talked a lot about the ABI record limitation and I think it's 998. And what a lot of people don't realize is that's 998, like, I don't want to say individual lines because it's not quite to that level, but every disclaim, every PGA is another record that counts towards that total. Okay, so if I have one tariff line, but I have to do an FDA disclaim, a CPSC disclaim, an EPA disclaim, that's now become four ABI records that that one entry line has taken up. And I believe if you have to do additional CPSC records, let's say, for example, I have a line of entry, it's just one tariff line, but I have, you know, 10 different CPSC records. That's now 11 ABI records for that one item. So just kind of keep that in mind because those can explode really quickly. You may find yourself having to do more entries than, you know, what you might have otherwise had to do just because of that limitation. Once you go to a model requirement for the certificate, there's an expectation that the nesting that you're going to see within an entry, it's definitely going to explode out the entries. There's no doubt. But as part of the beta pilot, we want to see and understand how this is happening and see how the process is being problematic in terms of our requirements. So that's why we're doing the beta is to kind of see how often that's happening and when it is happening, how can we adjust it if we can. So that's, that's part of the reason for the tentative work that we're doing. Sure, just read them off to further comment on DIS upload. Some test reports can be very large and this can result in multiple DIS messages or emails needing to be sent to CPSC officers in current environment. So I think regarding DIS. So we're not saying that test reports should be uploaded in DIS. When we suggested that a test report field for URL, we're considering other options because we know DIS is additional burden. So we want to see if there's an easier way for investigators to get access to these test reports in order to validate. So that's something we could work on as part of the preparation for the beta pilot. Will we start seeing CPSC may proceed messages being returned in a timely manner. There are several instances in which may proceed message hasn't been received for months after customs and other PGA releases. Yeah, go ahead. So that's definitely a two way messaging question. So to the individual who asked that question, if you are having problems getting a quick turnaround in terms of your may proceeds on two way messaging. Please send your information to the import team mailbox. We will input it in the chat after the next break and make sure that you have that information. So that address is imports with an S at CPSC dot gov. Is it imports with an S? No, it's not. Import team. See, that's why I wanted to look it up and make sure we got it right. Oh, I've been giving out their email. Yeah. So we need to just make sure we get a lot. We'll type in the right one after the break. But the window that you see on the guidance that is provided when I say window, the table that's presented in terms of the eight and the 16 business hours. It requires certain data elements to be shared across the CPSC and there have been times and everybody in the room needs to be aware of this. That the information exchange between CBP and CPSC does, you know, has a hitch and in those types of situations we've got processes to try to catch those. Not necessarily as timely as they could be. We try to identify that we're trying to improve those as much as possible. We know we've got a less than 0.1% problem with these nowadays is really been very limited. We have seen some hiccups recently. We are processing through some of those. So send your entry numbers to the email. We'll get it out to you in the chat. Customer service personnel are standing by. Any more questions? It just bounces up again. Someone asked, what is the process to sign up for participation in the beta pilot? Great question. Send me an email at a filing pilot at CPSC.gov. I can confirm this is the right email address. If you are an importer, please include your importer record number and the products you primarily import. If you are a broker's offer developer lab who are willing and you want to participate, you could also participate and send me an email. Ideally you would work in collaboration with an importer. So please work with your clients, speak to them. If you're a broker, you know clients that may be a good fit for this pilot. Please reach out to them on our behalf and send them even to our web page, which will be on the last slide of this PowerPoint so they can learn more. And again, we're seeking a subset of nine volunteers to participate in advising the IT development. If I could just add to Arthur's response there is we are looking for companies of all sizes, all shapes. It's important for us to build this in a way that's going to work for importers across the board. So getting companies, large companies, and we know from experience that oftentimes when these PGA pilots roll out, it's usually the larger importers that have the resources. They're the ones that sort of step up and we always appreciate that. But just in the idea of trying to get this right for everybody, we would. We want small importers, medium importers, large importers. We want companies that import through Express Consignment, which is we're going to be getting into the next segment. It's going to be on de minimis shipments. So we want everybody. You know, and we've got room in this pilot to be able to accommodate different size companies so that we can take all of that into consideration. In addition to that, companies who import different products as recall from that slide that listed the products that require certificate, it's across the board. And if you only, if you primarily bring in general use products, such as mattresses or ETVs, you're very welcome to participate. I mean, we had questions regarding posted furniture. So it's clear to me there are some furniture importers here. Everyone who brings in a product that requires a certificate, you're, we're more than happy to have you. And in addition to something I said earlier, if you only want to first start with a certain subset of your products, that's fine too. And then we'll work from there to add to what's being stated. If you know of companies, if you're a broker and you know of companies that don't necessarily have the wherewithal to show up to be one of the nine. But once it development has begun and we've got to tear and it's things are being built out and you recognize that there are smaller companies that could participate later on down the road. We need up to 50 to do the full beta. So, you know, keep those people in mind as well. Maybe they don't show up early on or maybe they can listen and advise early on and not necessarily participate with sharing data early on. But the idea is, you know, we'll get some companies to really help us and to test things out in terms of the IT area, nine of those. And then we'll add another 31 to 41 whatever to get to the full number that we're looking for. We're looking for a robust broader data poll than we then we got on the alpha for all the reasons that we talked about earlier. So, yeah, and if you already have volunteered, but you want to additionally volunteer for the nine. Please send me a follow up email e-piling pilot and cpse.gov. So I'll have a record of that. And so anything, anything. Okay. I think on that note, we could end this session in a little bit early. So we'll take a small 15 minute break here. So approximately we'll begin again around 225. Yeah. Thank you. Great. So we will begin with our last session discussing the minutes and direct to consumer shipments. Good afternoon everyone. Welcome back. We'll discuss the maintenance and direct to consumer shipments. The minimum shipments are those value under $800. Direct to consumer shipments are almost anonymous with e-commerce shipments. So either file type and type 186. 86 is currently voluntary, but it will allow the fileters to provide data. I'm not a paid staff. This has been benefiting the express delivery companies by providing streamline. Filling capabilities improving speed and efficiency. Prior to the deployment of entry type 86, the trade community was required to file a formal or informal entries when a shipment was subject to a PGA requirement. If any entry was filed, then duties, taxes and fees apply. For FY 21 about 344 million entries type 86 transactions were covered in the test. Based on the lessons learned from this technologies test, CVP is drafting a proposed rule to mandate a data set for the minimum shipments that will also sunset the section 321 data pilot and entry type 86 test program. The regulatory framework will serve to clarify existing regulations concerning the minimums and provide the opportunity to file for automated release of the minimum shipments, which include submission of the new and expanded data elements. These are data elements will successfully test through the section 321 data pilot and entry type 86 test. Current guidance is for the importer to certify compliance, but the importer is not always clear for the minimum shipments. CPSC is considering options for the importers. Consumers are not to certify compliance. And these are kind of the questions that we have. All right. So for discussion. These are the questions that we have. Will there be any difficulty on your end filing under entry type 86. I know CBP. This is still a pilot program and it's voluntary, but it is designed to allow for PG message sets to be transmitted via ace. So we'll like your input on that. And does the product registry address any de minimis or direct to consumer issues importers may have with product certification as mentioned the last slide. The current guidance is for importers to certify certify compliance, but when it comes to a de minimis environment that is not always clear. It was the importer. So we're asking for feedback there as well. So in this case, I will open the floor. Any questions or discussions. Say something under our statute. The certifier must be the importer. The manufacturer or a private labeler, which has a specific definition under our statute. So those are our 3 choices. So. Just kind of keep that in mind when we're talking about this. I remember back in the day, 2013, the common carriers. Expressing some concern talking about like overnight shipments and things coming across the border and that they, when they are acting as a broker, they wouldn't have. All of the information. So that was part of the impetus for the product registry. So now we have this registry where somebody else is putting in all the data and all you need to that reference number. So that's 1 of the questions. Does that sort of. Remove the issue like it can be. The importer now, because they're going to be putting that information into the product registry. But then we have this other issue of direct consumer sales coming from a foreign country. Right. And the consumer can't be this the person doing the testing and certification. Right. So who makes the most sense. And it has to be an importer. A manufacturer or a private labor. So what is your definition of importer? Is it importer of record? If it is importer of record, then there are a lot of non resident importer of records. Companies that are not located in the United States who act as the importer of record. She's also brokers who act as the importer of record. We currently and having the past and then the 2013 NPR. We said it was the importer of record. So that's the current definition. Our statute. Does not define importer. It defines the word import. It defines a manufacturer is including the manufacturer. And the importer. So importers kind of included within manufacturer, but there's no separate definition of importer. We've always thought it was the importer of record. So if people have, if other agencies use some other definition of importer. That would make sense for these types of shipments. You know, we're, we're looking to your experience. What do people think about that? What are other agencies doing? Can you give us some examples? Or does the product registry make all of this move? Maybe I'll just sort of open it up. A question also. So for. Those workers, importers that have been filing under E T 86. In attaching PG message that data. How's that going? I mean, are you finding that it works well? It's a, it's a reasonable way to, to provide the PG message. It's a, it's a reasonable way to, to provide the PG data when it's, when it's required. All right. Kat, do you want to go ahead? Is the de minimis for a single item or multiple items as long as the value is under $800. Jimmy, you want to take that? That's a question for CBP. Okay, I got it. I believe rules about de minimis is $800 per shipment per person per day. So it doesn't matter if you've got a thousand widgets. It's $800 value per person per shipment per day. So thank you. And I had another question. Give another one. Yes. What's the current process for collecting certificate data for direct to consumer shipments and. De minimis shipments. That's something we want to learn from importers who bring in de minimis shipments. I mean, the. As mentioned, like we do not have a de minimis exemption. The certificate is required, but we do catch into de minimis environment and said come in with no certificate and our investigators request a certificate and no certificates provided. So. And we do take enforcement action under those circumstances. Yeah, there's a question right there to my right. Hey, Kelly from sunny days, we are, we do a lot of direct import shipments and our customers, they are the importer of record. They require that information from us upfront. They're requesting that so they can import flawlessly with no, no issues. Issues. So the follow up. Who in that case provides a certificate. We're providing it to them. You say, okay, so you are the one certifying the certificate. You just hand it over to them. Okay. So in your scenario, you obtain the certificate from the manufacturer. We're the manufacturer. You're the manufacturer. Okay. I didn't understand your role. Sorry. Okay. So you as a manufacturer providing it to your customer. Which satisfies what we've said is the entities that can provide the certificate. So that's a consumer. Like Walmart. Oh, okay. But do you import directly to a consumer? No, not to consumer. Just retailers. Okay. Yeah. So we're very, so in that environment, I think it's rather clear how the process works and we're very concerned about in a diminished environment where it's being sent directly to the consumer. So like sent to someone at 123 Main Street, that consumer won't know the compliance rules that we have. So we therefore say they don't, they're not the ones responsible for certification. So we're trying to determine how do we ensure that product is saved before it gets in the consumer hands. If it's a de minimis or direct to consumer shipments. Yeah, that's not our model. But thank you for your input. Let's go. Oh, you go ahead and I'll go to the computer. Hi, I just have a comment on the importer segment. As discussed previously, the Iowa and a lot of situations could be the broker, but even in situations where it isn't like I come from a conventional background, working with northern border shipments from Canada into the US. A lot of times the IOR can be an individual business or a chain of businesses in the United States. And they're really not familiar with the details of the product, where it's manufactured, how it's tested, things of that nature. I would strongly encourage opening up who is able to provide that certificate or fill out that information online, perhaps to include the exporter or the manufacturer. And even to allow them to certify it because in most instances they are the one who has the technical knowledge of the product. The IOR may have no technical knowledge of the product and not be involved in the lab testing process whatsoever. Thank you. The importer record under the regulation must gain that expertise in order to certify right so they're not doing the do care that they're supposed to the manufacturer can certify now. They can test, they can certify, but the importer, if they're importing it into the United States, they are responsible for obtaining that expertise, asking about the testing, having access to the test report. So they should be doing that under the law now. That is your obligation. If you are filling that role and you are taking money to fill that role, that is our expectation. You are performing that duty and all of the duties of the importer record now, but we realize with the minimum shipments, it's a little bit different if the importer is actually a consumer. So, right. So in that case, you know, this is your idea. I think it's to open it up to the manufacturer, even for imported products. So that's the kind of thing. I mean, that's one of the people. There's, we had 3 people. 2 of them are defined terms manufacturer and private labeler importer, as I said, is not defined in our statute. So, is it defined somewhere else different than what CBP defines it. I think we're interested in hearing about it and what other agencies do. And we do already have the ability to use the manufacturer. If that makes sense. This is the last question I have is if a product exists in the product registry registry will an entry type 86 be required for any direct to consumers ship. Well, yeah, so the register only maintains the certificate. And so you have to essentially inform us when you import that product that there is a certificate for that product. So you would use the entry type 86 and that and that scenario. Certificates are stored by importer right by the imported number and by product ID on the registry. Yes. Right. So how would like we use it on entry type 86. Right. Without knowing who the importer is for entry type 86. I know that PJs are able to request for the IOR. But that also opens another question. Should it be? Should we define importer as the IOR and that's an area. So to add to what you're stating, if you're if you are acting as the broker for the importer, you could set up an arrangement where you can have access and knowledge of the certificates for that importer. And under that role, you would be able to express the certificates coming out. So, you know, you would have a sub account where the importer would have the main account. And the expectation would be you'd be able to see those those certificates. That's in a normal, you know, commercials type situation. And the situation like we're worried about in this where, you know, Jane does your actual physical consignee. They're the ones that acted to ask for that product. It's coming into the country from some foreign manufacturer and it gets routed through you as, you know, the the express group. The difficulty just ends up being where do we make trace? You can't get to that. You can't get to a certificate in that situation. So for us in that situation, we would have difficulty matching it to anything that might be in the registry under some other importer's name, because we don't have record that that product exists for Jane Doe. Or unless the manufacturer lined it up and you would then track the manufacturer within the filing. That would probably be the only way is that the manufacturer then loads it up and says this is going to be a the certain number for this product in my D to C situation. So maybe we have to make D all D to C then be reliant on manufacturer direct for I mean that these are the kind of conversations we have to have. So if we're expecting foreign manufacturers to be doing D to C all the time, if they don't adhere, then we're stopping those products. They're going to be at high risk of being stopped because they're not going to be able to provide us a certificate because there's no linkage. And if in an express environment it comes through, it's it's going to be a higher risk importation. Yeah, because well, I think that's what we need to work through with you. I mean, honestly, right, because then that's where the difficulty comes in is because we don't necessarily always have a relationship with either party. You figure that, you know, people are just going into a, you know, express consignment carriers office and dropping off a package. They don't have any relationship with the manufacturer or the consumer. Understood. And part of the issue also and to add to what Jim's writing right now, I hope is going to be the fact that we also have to deal with the same problem in the mail setting. So you've got situations where people send a product to an individual here in the United States, let's say from France. Okay. And it is a product that we're concerned about in that type of a situation. Who's the responsible entity to provide the certificate that's going to be an issue even in the mail environment. I would argue it's the senders probably the senders responsibility, but we haven't tackled that. They're the one acting to send the device to the recipient. But that's not law. We have to talk this through. We have to think this through and that's ultimately what we learn here is going to end up getting written into our wrecks. And I was going to say, and they might argue that it's the person who is purchasing this item on a website somewhere that is causing that shipment to come into the United States. So can I just ask like sort of setting aside CPSC other agency. So if there is a de minimis shipment that's coming in and say FedEx is the carrier for it, right? How do you know if there are PG requirements for that particular product in that shipment? Is there a way. I mean, I'm just thinking, you know, they're there. They're there through extensive automation and manual. Okay, so there you have a process. And so, so you have a process to sort of identify this is likely going to require PG data. And then yeah, then you get kicked over right in a in a very short turnaround with with wheels up and around. Okay, so that's kind of a survival. Okay. Okay. Can I add to that? There's a there's a great example here that I think you could. Okay, so a private farm in France, I'm going to use them again, sends cuts of beef through FedEx packaged into the United States. How is the requirements fed for FSIS FDA tracked in an express type environment? It's the same. It's it's it's the same requirements. It's the same issues. And we just aren't seeing it. And we're not sure how that's being implemented. I mean, you could do the same thing in terms of, you know, drugs sent from France into the United States. How do you pick up on that and say a FDA needs to see this product? And if you're doing it based off of AI only off of a product description, can we do better? I mean, because there's a lot of issues here. So that's that's also my question to you. I have a follow up question to that in your scenario. I can tell you as a mother and a consumer and someone who orders a lot of stuff online, I can't tell you how many packages I've gotten in that have come from China that have one thing written on the package. And it is nothing to do with what's in the box or envelope or what have you, you know, so I think a lot of these things are just they're getting through. Without any PGA considerations whatsoever, because at face value, it appears like there aren't any, but we all know that, you know, a lot of these products, they there definitely are. So my follow up question was given the whole process you have, who would you identify should be responsible for not just CPSC before other agencies if they're like similar requirements. So like in John's example, like, who is responsible, like sending the data to FDA or FSI as about slice of lamb chops being sent from France, like, like, that's where that's where we're trying to get to put you on the spot. So I'm just like your insights. So so just recognize that we as a group, not just CPSC are struggling with this and we recognize that the shipments are getting smaller, that D to C is much bigger and is growing by leaps and bounds. If you take a look at our e-commerce report, we recognize this pretty heavily, and we're all trying to trying to tackle this. And I think part of the risk ends up being that it's easy to take a look at a large commercial shipment that's slowly going through the port of Newark. It's really hard to get to those overnights, and I can split a large shipment into a thousand small shipments if the cost is right, and the timing is right, and I can avoid federal agency oversight. Then all of a sudden, you've got some major concerns there. So this is something that we're keeps us up at night. And, you know, as something that we really do see longer term, you know, you're going to have an outbreak of a product that's just going to be a problem that is going to be split up into single units. And we've got to be able to have coverage because we're declaring that we've got responsibility. So just something to put out there. Flores will open any comments or? I was just going to say, as you ponder these things, remember, if you don't have the answer today, we're collecting comment through November 14th, I think, 11th. So feel free to file your thoughts on regulations.gov. If you have them, if it comes to you on your way home, we welcome any enough thoughts on these issues. I think the, you know, the, the minima shipments and as John mentioned, mail shipments is, is another world all to its own that needs to be figured out separately. But, you know, this is one of the one of the real significant issues that we want to make sure that we're that we're handling and that we're identifying who the responsible party should be in conversations with CVP about definitions and things like that. So, you know, I think this will continue to be a topic, you know, please submit comments to this and, you know, I'm sure we'll have follow up discussions as time goes on as well. And we currently primarily define the importer is importer record per CBP definition, but I know CBP has a separate definition for importer and other agencies have different definitions. So we would like your feedback on that too. If you find that one agency kind of gets it right on who the importer should be, especially in the minima's environment will like to hear from you that would help inform us. If you have different ideas, let us know. I mean, when we get to the cusp to it is someone needs to certify and who should be responsible. And the only person we kind of ruled out is the consumer is wants is a CPSC person showing up and saying, we're taking that product from you. That's the last exactly. Yeah, we're not taken from little Tommy or a little Debbie. There's no way we got to get to it before that happens. All right. I mean, the remainder of the time we have left this afternoon session has gone quicker than expected. I will open the floor to any other comments, questions, remarks you had from any session throughout the day from the morning sessions. And as you think about that again, you want to participate email me here. Okay, I'm going to throw out a question if you're not all going to ask. Does have a question cat. You've got a question. Good. Is it safe to say prior to now CPSC isn't collecting any certificate data or very little on direct to consumer and de minima shipments. I would say that it's very, we have people at investigators at express consignment facilities. So we have some data where whether a certificate is available or when more so when it's not provided with the de minima shipment. When it comes to like the details on the certificate, I mean, that's the purpose of the following be able to actually incorporate that data to risk modeling because when something comes in as a PDF like our investigator can look at it. But if it's not data ties in any way, we don't have the ability to actually use it for something meaningful, meaningful. Yeah, I mean, I would just add that, you know, over the past year and a half or so, we've had legislation that's directed us to address e commerce to play staff and e commerce imports where de minima shipments arrive. That as resources have become available is a big focus for us. So we do think our. Our work in those areas is going to is going to expand again, you know, we're we're a single funded agency with a relatively small budget. And, you know, so we really work at when, when, when money becomes available staffing becomes available. That's that's really going to be a main focus for us. Moving forward, I would say, you know, in the work that we've done in the de minima environments. We have found no shortage of certificate violations. You know, we ask as part of a normal we don't receive that that information electronically right now in advance. And so we do request it when we stop shipments for examination and it's there's a pretty high frequency of when the information is not available, which I think just sort of goes to, you know, you know, a lot of the shippers are are not aware of what some of the CPSC requirements are out there and that this requirement is out there. So it's a, you know, there's certainly an educational aspect to this as well. And that'll come out, you know, through the work that we do now and through the rulemaking process to make sure that people understand what the requirements are. So when you get one of these de minima shipments and you pull out the package and you see it's supposed to have a certificate, I mean, what do you do at that point? You try to get the certificate, obviously, but then if you're unsuccessful, do you do you start then to educate the manufacturer of the shipper? How does that process work? Yeah, I mean, a combination of those. We do ask for it if it's not there. We sort of have a progressive enforcement posture towards certificate violations. Oftentimes with the first one, we with the first violation will inform, will educate, try to get them in line after that. Oftentimes it's working with CBP to have that shipment seized. For importers following option one product registry, how do individual subsequent shipments under that, under that, under that registry number get tied to the previously registered product? So I understand the question when using option one, which is using the reference message set and product registry. So if you're bringing in a subsequent shipment, which would be in a next entry, you could reuse that and you're bringing in the same product with the same certificate, you just enter the same registry ID number into that entry. And for the person who's asking the question that the registry information is going to be stored within CPSC, the entry information is being obtained by CPSC. And so as that information comes in and the reference number is attached to the entry, every time a reference number is provided will be pinging up against or checking against the registry to be able to say that this has or does not have. Information and that the information is up to date and we'll do a whole bunch of business checks and so on. So recognize that this is an anticipated architecture that we're going to have in the next year or two, that these systems will talk to each other constantly. And so once it's in the registry, you put it in once, we're going to, every time you file, every time that date is filled out, we're going to be pinging up against the, in essence, what this reference table is going to be providing. Any more remarks or questions? See, Michelle. One more. So since the HTS number is not part of the product registry, are you going to do any sort of validation say I, you know, transmit product registry number 123 today under a chapter 95 tariff and then tomorrow I do the same number under a chapter 34 tariff whatever I'm just making it up. But I mean, are you going to be auditing those things? Am I going to get a reject on my next entry? Because it's going to say, you did this yesterday under, you know, it was a toy yesterday. How is it a mattress today or, you know, whatever, you bring up two points. Number one, yes, we're going to have analytics in place that says that if you put this down and it's classified in a particular way, the expectations, it's always going to be classified in that way. Number two, if it gets misclassified in subsequent filings, you know, there's going to be lots of business will checks will be able to do between the information and that's part of the robustness of the filing program is that we'll have these consistency checks that are going to make life a lot easier for us because we're going to understand, you know, under 9503, you need to be doing all these, you know, validations and you're going to put the citations in place. That's going to be the expectation for that for that toy. Oh, you're going to throw it under, you know, 3926 is a plastic item now. Well, no, that doesn't work because, you know, we're going to have a business rule that says, No, this isn't a decoration. It's a toy. And so at that point in time, we'll kick it through and we'll say there's going to be issues. How we decide to act on misclassification, we're going to have to figure that out between us and CBP because misclassifications one issue. If the toy is a toy is a toy, and it's always coming through, but you change the HTS codes, it may cause some confusion and some heartburn for the system. But in terms of misclassifying product that's classified one way and we're expecting that information and only citations go to certain HTS codes, longer term, we're going to have those business rules in place. We'll be checking those in terms of follow up, misclassification is a CBP issue. I would argue you'd probably be at higher risk for examination if we see an HTS code that ends up being a problem because then you're telling us something's changed. And if something's changed, the product probably has changed. And at that point, we want to understand why. So you're going to have business rules then that'll say a mattress tariff should be only certified under these citations and not under, say, a toy citation. So would that be like a bucket one validation then that just says that's just not a valid combination? That's bucket two? That's going to be a bucket two check. Okay. Bucket one check is going to be. Did you give me a number? Data improper. Got it. Okay. Thank you. Thank you. It's an interesting discussion, but one thing I just want to make sure that everybody understands is that we're asking for and ultimately requiring this information so that we can do targeting for health and safety purposes, right? We're not targeting for misclassification. We're not targeting for other issues for other agencies potentially. We're looking for, you know, shipments that are at risk of being non-compliant with CPSC requirements. So I just want to make sure now if we find misclassification issues or IPR issues or something like that, you know, we could potentially refer those to the appropriate agency to handle. Right. And there's a correlation, we believe between misclassification IPR and health and safety longer term. So we would kind of watch that in the business rules. Great questions. I can speak loud to just to clarify, though, there are legitimate reasons why a product has changed tariff classifications. It could be a court case. It could be a binding ruling could be many different things. So it might not just be that you were trying to avoid reporting to CPSC so you jumped from toys to plastics. So just that caveat. Understood. Okay. Understood. And it would be on a case-by-case basis. We would have to spend the energy to go and ask those questions. So do recognize that as well. Well, we still have time. The floor is still open. Thank you so much. I would just like to clarify my comment from earlier regarding the IOR. Well, it is the IOR's responsibility to ensure the classification, evaluation, things in reference to duty are provided correctly to CBP. There are plenty of PGA's that do not require the IOR to be the one who's providing the information. And I'd just like to go into, for instance, prior notice, which as we all know is very important with FDA processing. This is directly from their website. They allow anyone who has knowledge of the required information about an imported shipment to submit that information through the PINSE system. That includes information about the product, quantity, packaging, related facilities, manufacturer, shipper, owner and other information. So that's anyone who has knowledge of the shipment. And that's why I was urging more to allow more parties to submit this information and not to define the importer strictly as the IOR. And maybe not even to define the party that has to provide it as the importer whatsoever. So, go ahead. I was going to mention, so there is three options of who could certify the importer manufacturer, the private labeler. And as Mary said, the definition importer hasn't been defined. We previously used the IOR and in our proposed role in 2013, we wanted to codify that, but we put that rule on pause. So, we're open to other suggestions. Thank you for providing that as a suggestion about the FDA prior notice example. And that's what we're trying to get to, like, we as you want to figure out like who's actually responsible in the C environment, like, or in the formal entry environments, rather clear. And for the issue we're having is the Minimus environment. Yeah, I just want to caution that, you know, each agency has its own statutes. Right. So they, they probably have different authority. Our authority, we have 3 people. So we have to, we want to take in all the information and consider it, but we're just letting you know it has to fit within 1 of those 3 buckets for who's responsible. Hi, again, could you please clarify what the subset of 9 volunteers will do different from the participants are separate from the participants of the beta test. So those 9 volunteers will work more closely with the IT developers and provide probably more detailed feedback. So ideally someone, one of those volunteers would be in a firm who's going to be working on the IT development portion of it, the software development on their end. That would be an ideal candidate for this subset of 9. And I imagine this would begin rather shortly in the next upcoming months because as I showed in the schedule. We want to develop the catare or draft the catare by February in order to begin development on CBPs and but also allow for software developers to begin starting in March. Early round trip testing early documentation validation. Just those 9 would be just stepping up early and just making sure that we've got a lot of the core stuff. You know, the basics down before we get to the nuance stuff that we'd be doing with the larger volume of data throughput. Yeah, and this is not to mean that other volunteers won't have a lot of interactions with us. You will. It's just, we're going to look at who are the volunteers and gauge them in different ways. So a software developer be gauged differently from a broker to importer as part of development for the beta pilot, depending on the requirements. But does my strong push for the IT developers at the, if you have, if you are from the house that working on the coding or the software that would be an ideal candidate for the subset of 9. So for your subset of 9, do you have an idea of what that mix would look like? You know, are you looking for, you know, one software provider to brokers and, you know, six importers or, you know, 333 or you just don't. You're not sure. Just wait and see who steps up. Yeah, who steps up. And earlier you informed me the better because we want to get working on the guitar as soon as possible. And when it comes to the other volunteers, I know I spoke with a few brokers here today that they have some clients in mind. Yes, please reach out to them and provide information to them about e-filing. But if you can't get me their names until like down the line a couple of weeks from now or a month or two from now, that's okay because they will still be engaged throughout the process. As I showed in the schedule, there's different steps and of course software development is the first step after that would be onboarding participants and testing out the features. And let me, if you want to find more information, go to this website, cpsc.co forward slash e-filing. And that has everything that I have presented previously at other public meetings and forums, those handouts that are on the table that will be available on this web page as well. And then once our A.V. team finalizes everything, we'll get this recording available on our website as well as this PowerPoint. That's my promise. Okay. When you say nine. What? I'll hold you to it. When you say nine, is it like nine individuals or nine companies? Well, it'll be a company that's a participant. Okay, so as a participating as a company and then you can have multiple individuals within the company that can participate. Yeah. We look at the volunteer as a company. Got it. Okay. Thank you. Go ahead, Kat. A couple of questions from chat. Do you have a matrix of what products are currently classified with HTS codes against the certification, then automate a red flag. If there is a mismatch. John, do we have that? Oh, sorry, don't mean to be that flip. We have HTS codes map to product groupings at this point in time. I think as we get more experience in terms of mismatching and, and so on, that's going to, that's going to take some, some work. But right now at this point, we've got an idea. We'll probably sit down over time and see what HTS codes we're going to include in this overall process. But in terms of what codes get mismatched and how and those business rules, that's going to take analytics probably in the next 6 months. We'll probably figure some stuff like that. Who knows. And what are the next steps after the workshop? Next steps. I know to be a participant. If, if you participate, you will start to hear from us, myself and the team here today. But in regards, if you, yeah, that's just my plea. Our next milestone to be development of the Qatar by February. So that's why I'm urging individuals who want to participate that be in the subset of nine. Of course, if we have more interest in that, I have to limit it only to nine. But in terms of the participants for the beta part itself up to 50. And so, depending on who you are, we'll gauge you throughout the process throughout the development throughout the testing throughout the onboarding, et cetera, et cetera. We have a team here who we will develop business education material videos, et cetera. So, and like reference documents as well, we'll get you the HTS list, the citation list, all that information well before the pilot begins and work with you along the way to get to that point. Just want to make sure folks understand sort of the timeline as well. So, Arthur's noted, you know, we'll start collecting data under the beta pilot in about a year from now. Next October is the target. We are planning this fiscal year to, we are planning this year to issue the notice, the supplemental notice of proposed rulemaking. So that's going to provide, you know, a lot more detail on the path forward with e-filing. So I do think, you know, in terms of, you know, early involvement in this is going to be critical because it not only will help inform the beta pilot, but also is going to help us to answer some of these questions that we're going to have to answer for rulemaking, or at least for the proposed rule. So, so just another plug for trying to get involved early. Anything else? Okay. Will this presentation be made available to email to participants or made available on the website? It will be made available online. Thank you. That I can. Okay, so I think I'll close this workshop today. Thank you all for participating. And those of you in person for coming in, even though the under storms appear today. We really appreciate all the feedback you provided us. We're trying to, my hope is this e-filing and the beta pilot be huge success and it would be seamless. We're able to get this up and running smoothly without any issues. So all your participation will be very, very helpful. Any remarks, Jim? All right. And so I'll end it on that. Thank you once again.