 for the Office of Imports and Valens, Sabrina Keller. I will provide a public disclosure next and then provide an overview of the beta pilot. Go over the timeline, your expectations and consideration as an importer. I also preview the IT DAG working group who has been working with us already for the past several months. This is a group of nine importers who have volunteered their time to work on the IT development aspects. Then I will cover some of the support CPSC will provide and the resources we have before I go on to discussion and a Q&A session at the end. This meeting is just a welcome meeting and onboarding session. We will not go into too much detail about the registry or the message that per se we're gonna keep it high level, but in the next several weeks over the next few months, there will be more training sessions and more materials sent out to all participants. So welcome again. And I will pass the baton to Deputy Director Sabrina Keller for a few remarks. Well, thank you, Arthur. Greetings, everyone. My name is Sabrina Keller. As Arthur mentioned, I am Deputy Director of CPSC's Office of Import Surveillance. I would like to start with just a few words of introduction. Firstly, to warmly welcome you to this initial meeting of the e-filing beta pilot volunteers. And equally important to thank you for being committed to consumer safety and for partnering with CPSC on this important initiative. This is such a critical project for our agency. And I would say for American consumers overall because your candid input during this pilot will help ensure that we get this right and will ultimately contribute to public safety. So we've got a great team here. We're always available for any questions or concerns as we work together on this. And with that, I will turn it over to CPSC's e-filing program specialist, Arthur Laciak. Back to you. Thank you, Sabrina. And I don't think I could have put it any better. I just want to reiterate how important this project is for our office, for our agency, including for the commission, our commission who will manage the agency. They are very excited about this project and very excited to have all of you participating with us. We hope this turns into a great success down the line. Just one note, please hold off all questions until the end. And when you do have a question, please raise your hand and I will call on you and then you could unmute yourself. We do have close to 100 participants on today's call. So I do want to be able to manage who's speaking. So a quick public disclosure because this is a project that we will be presenting on to the public, a list of all participating firms we made available to the public and later published in a final report upon the completion of the beta pilots. USC, the main participants here are the importers, but they are allowed to work with their brokers and after third party collaboration for this project. So they and any of their third parties would be their names as participating firms will be later made public. Second, participants will be requested to provide feedback and share experiences in regular current group meetings attended by all beta pilot participants. These meetings will be scheduled beginning in about two weeks or so. And throughout the summer, we will keep you apprised with all. We as in my team will keep you apprised developments across the next several months. I would talk a bit more about the timeline later on today. Every meeting will be published on CPSC's public calendar and anyone from the public can attend the meeting as a listen only attendee. We will also be recording most meetings including this meeting for individuals who are unable to attend. However, only beta pilot participants will be able to speak. That means that anyone who wants to attend just as an attendee will only be able to listen. They would not be able to speak up during that time. Participants during these meetings will not be asked to share any confidential business information. The only feedback we request is in regards to e-filing in regards to the e-filing system including the message that the product registry and anything related to that. And participants will be requested to respond to surveys from CPSC staff. These surveys would be sent out prior to the beta pilot and throughout the pilot and at the end. So very quick overview. Beginning in 2020, October 2023, excuse me, CPSC is conducting a six month beta pilot test to test the e-filing system in order to test the electronic filing of product certificate data. We expect that e-filing will be fully implemented by 2025. So this beta pilot, as I mentioned, will consist of at this point, approximately 40 importer participants and their industry partners, which would include their brokers, labs, software developers, et cetera. Any partner that the importer feels is necessary to assist them on this project. Again, the importer participant though is the main participant and we will be fielding most of our communications via the importer. The beta pilot will test the e-filing system and participants will provide feedback to CPSC to inform the final system development and rulemaking prior to full implementation. My team is currently working concurrently on a rule that we will propose towards the end of this year and finalize after the beta pilot finishes, we will take the results of the beta pilot to help inform our rulemaking. And once the rule is also proposed, you as a participant or just a member of the public will be able to provide public comment on that. And when it comes to e-filing, there will be two means of doing so. The first is the full PGN message set, which is to provide all certificate data at the time of import. The second is the use of the product registry and the reference PGN message set. That is to pre-file your certificate data in the product registry, which will be a database that CPSC staff will maintain. There you would retrieve a registry ID and you would submit that into the reference PGN message set. We find this as a best option if you bring in the same product and repeated shipments using the same certificate. Using the second option, you file the certificate once and then file a reference to it in the message set. If you choose to do the full message set, you have to repeatedly provide the same certificate information for any repeated shipments. We have broken down the participants into three roles. The main role, of course, is the importer. They will be the ones who will be coordinating with their customs brokers and we've identified some kind of tasks and responsibilities for you. We ask that you during this process and over the next few months, consider your internal business process development to be able to incorporate the beta pilot and e-filing. We ask that you set up a business account when the time is ready in the product registry. We also ask that you kind of review your processes of managing your certificate data and how you plan to submit that data via the message set. You will, of course, work with your brokers in many of these tasks, but the broker's responsibility would be to review the e-filing infrastructure development and testing, also have some role in the data management and also will be filing the data via the message set. As I mentioned in the previous slide, there's two ways to file. We are building this e-filing system in a way that is very versatile for all the types of business operations that we expect to see in all the different types of, or all the different depths of relationships we expect importers to have with brokers. So in the product registry, you will find that there is ways to provide permissions from the importer to their brokers or other trade parties to provide them permissions to file this data on their behalf and certify on their behalf, but the importer would be the one who will manage the permission levels. They could either provide most access to their brokers and other partners, or they could limit the permissions and they would be responsible for filing the data into the registry, or you could opt out from using the registry to file the data using the full PGA message set by submitting that data via your broker. When using the registry, you would also have the option for bulk and EPI uploads. So we are truly creating a system that is adaptable to many different business operations and throughout the process, we will ask for feedback on the e-filing system as a whole. Third, I have here our self filers. In short, a self filer is gonna fulfill the role of importer and broker. So I'm not gonna repeat the bullets listed here because they are the same as to the left. So anytime I speak of importer or broker, if you're a self filer, just note that you're taking on both roles. Below is a timeline of key activities for beta pilot participants throughout May of 2024. So I'm gonna start at the bottom where you see this little rocket ship. That is the launch of our e-filing beta pilot which is expected on October 1st. The pilot will run for approximately six months. So we expect that to end in or around April of 2024. During that time, you would be testing the e-filing system to its fullest potential using actual live certificate data that you own, submitting it via your broker through the message set that do this and through CVP and then comes to us and we will be using that data to improve our risk assessment and targeting. During that time, of course, you would provide us feedback and we'll be there available to answer any of your questions especially if you run into any hiccups or have any concerns. Well, let me address what we have already developed. On this timeline, you don't see the earlier months of 2023 but during this calendar year so far, CPSC staff and its developers with assistance from CVP have been actively working on IT development with the assistance from the IT Development Advisory Group. This group is a working group of nine importers who have volunteered to assist in the IT development. So their assistance essentially helps to establish an integration print that CPSC is developing to be used by all beta pilot participants. They already previewed and provided feedback on the e-filing product registry features as well as the PJ message set. They will be the first to conduct cert testing of the PJ message set and test registry and the feedback and lessons learned from their testing will help inform us over the next few months and prepare us for the beta pilot so we could train the remaining participants to use the e-filing system. Going back to this timeline, in the month of June and through July, we have been focused on development integration and the e-filing application preview and cert testing has been open for the IT DAG group. The cert testing is testing done with dummy data. No real data is actually submitted and it's just a means for the developers to test the PJ message set. At the moment, the message set is available for testing with CVP. However, the product registry is not yet available and will be available later in June or the second week of July. And then at that point in August, we'll begin live production testing with that group of nine where they will submit real certificate data into the system. And in the months of August, September as you can see below in green, that's when the remaining participants would be onboarded. They would begin their system integration and testing and participant training on this call. There's, I said, parking between the importers. There are fewer brokers because most brokers have multiple importer partners participating in this. Some have already been participating in the IT DAG. So if you are an importer who has a person a different quarter in that case, they will also be able to help onboard you into the e-filing system and throughout the training and onboarding process will be particularly focused on working with each and every single one of you, working on your specific needs of onboarding. We will have training sessions throughout the summer. We'll provide SOPs and business education material, but we'll also be open to have one-on-one meetings between you and your broker so we can help iron out any kinks that you may have and work with you through the system. Your expectation as a participant for the summer 2023 can be broken down into these four bullets. The first is to determine which HTS codes that you would file for. On our wage at cs.gov.com slash e-filing you could find a list of HTS codes of approximately 265 codes. However, these are not all the codes you filed the certificate under. These codes is only a subset that we would want to test in the pilot and that is based off of our targeting HTS code list. However, there are many products that require certificate that may fall into other HTS codes. You are able to and we actually highly encourage you to file certificates under different HTS codes if you find that necessary for that particular product. We do wanna see the whole universe of which HTS codes would be affected by this e-filing requirements. So by filing for any HTS code that has a certificate, requirement will actually assist us in knowing which HTS codes we would flag once e-filing is fully implemented. I mentioned about HTS flagging. We will not flag during the pilot because it is limited to only the beta pilot participants and flagging is a universal flag that would hit every importer, importing under that HTS code, therefore we don't wanna cause confusion and flag all and begin flagging importers in advance of the full implementation. We will hold off wagging until that point. We also will have a final draft to get there. Early on the webpage, we do have a almost completed version available. Later this summer, I will release the final version prior to the beta pilot. But for brokers and self-filers, you should review the Katerin order prepare your IT team for integration. What I can say is that the Katerin that's already available online is pretty much complete. The only, throughout the summer, I expect to make some small tweaks and changes, but nothing substantial that would affect kind of the core of the implementation guide. Third is the required e-filing data elements. I won't read through all of them because these are the same data elements that are already required on certificates as of today. And in the registry and in the message sets, you would have the option, you would also have the option to file additional certificate data elements, which of course will all remain optional. Those data elements will help you or intend to help you keep track of your certificate data, but it also will help us in kind of informing us how best to analyze the data. Of course, besides the seven data elements listed here, the remainder will be optional, so it's up to you if you wanna provide that. And as I mentioned, the product registry will have an option for a CSB bulk upload and an API framework. The product registry itself will be a web application for user interface for individuals to submit certificates one by one. There will be features built in to make the registry very user friendly, which includes notifications to do list, copy and coding functions, editing functions, et cetera. But the CSB bulk upload and API framework will provide you the ability to submit multiple certificates at once into the registry. We will have additional training regarding the registry later this summer, so please hold tight on that. We also want to provide some considerations. These are lessons learned from the Apple Pilots, and so we would like you to consider these bullets as part of your internal planning efforts. For one, please consider the software update requirements implementation. You would want to identify requirements and timelines to integrate systems and access the necessary certificate data and to engage software teams early because software updates to existing broker systems can take several weeks to implement. For internal business processes, during the beta pilot planning development phase, you want to anticipate the on-born internal meetings and internal planning activities that have a higher time and resource requirement, the beta pilot test should require a lower resource burden. At that time, we mostly land on brokers and their software developers, and once the beta pilot test kicks off, some of the burden will be on the importer, but we do ask that you plan in advance for this. We also ask you develop plans to process the coronation data and mapping a certificate data system and associated timelines, and to identify resources and established timelines for gathering, applying, and reviewing certificate data. This really comes down to how the certificate data is already managed on your end. I've anecdotally learned from importers that some already have an electronic format, others have their certificates in a PDF. E-filing would require that the data be in an electronic format, so of course, if you have an PDF, there would be more work there necessary in order for you to translate that data into a usable format. However, that product registry will assist you on that, so you don't have to create a new system on your end. A lot of software development is regards to the broker's interfaces using the automated broker interface, connecting it from their systems to CBPAs. And we also ask you to consider competing priorities that may affect resource availabilities and timelines. Excuse me. Throughout the next few months, and the beta pilot will be here to provide you support. Later this summer, and prior to the actual kickoff of the beta pilot, we will have an official kickoff meeting. Today is just a welcome meeting. We also have one-on-one meetings with participants who address individual concerns and questions, and these meetings would be between you and your broker and any other partners that you require to have on these. We would also provide technical support throughout the next few months in the beta pilot who will provide training, business education material, SOPs, videos on the product registry and the message set, and we'll be here to answer any of your API development questions. And lastly, in regards to the message set, I'm repeating myself. We will be here to answer any of your questions and to troubleshoot. Brokers also have access to their CDP client reps who can help you with specific questions directly related to the message set. That is not to say that we won't be here to help you, but they may have a quicker answer if you have a very specific question related to the message set. To message set system as a whole, questions regarding perhaps to Qatar, you could send to CPSC. We also will assist whenever any of your shipments are flagged. These flags during the pilot are just error flags, they're warnings. None of your shipments are gonna be held as in regards to the beta pilot. We are just, these flags would just be issued when we find that there's an error in the data. This could be a formatting error, this could be missing data, this could be data is not matching, et cetera. And we will provide all those business rules at a later date so you know what those error flags will be. We're still actively working on that with CBP. And when you receive that flag and you don't understand it, just please come to us and we'll help you understand that. And again, I wanna say we are not, we are very happy to have you to participate. So none of your shipments that you provide that you filed for during the beta pilot are gonna be under extra scrutiny. Like we understand this is you providing support to us and so we are very grateful to have that. However, as a small caveat our normal enforcement operations are still in occurrence and if you have a shipment held under our normal enforcement policy, that's something else separate from the pilot and that may still occur. But if it does occur, we will try to prioritize your shipment for review and exam. I've discussed this in the web page though is cpsc.gov forward slash e-filing. There you would have find the implementation guide also called the Qatar, the list of HTS codes. You also receive information regarding testing and certification and the which of your products requires certification and which testing must be done. Please be mindful that there are two different types of certificates and children child product certificate and the general certificate conformity and those certificates very similar but have different requirements. And sometimes both certificates can be applicable to a product just depending on the age grade of the product. Additionally, we have a resource here about a future case scenario where we are working with GS1 to be able to access their data from the global data synchronization network. The hope is if our certificate data is available in the GDSN cloud, we're able to access that data. And if you provide a G10 to a product, then we will access that data from the cloud and you would not have to use the registry or the full message that you would just file the G10 to us. So that's an exciting development that we're working on. Please keep that web page bookmark because any additional resources will be provided there including as I mentioned some of the business education and tutorials, SOPs, et cetera. So with the time remaining, I will open up to questions and feedback but before I do that, I'm just gonna address the next steps. So CPSC will complete the IT development and filing system and share requirements with participants. Please keep your eyes on your emails because over the next couple of weeks, we'll send out invites to training sessions in the future and provide you more information. We also will schedule a kickoff meeting and additional onboarding. I think we'll have your quick considerations in the welcome packet that you should have received. And if you have any questions, don't hesitate to reach out to us. The email address is in that welcome packet but for you on the line, it is e-filingsupport at cpsc.gov. So I'm gonna open up to questions and if you raise your hand, I should be able to see it and I could call on you or if you like, you could type in your question to the chat. So I have a question from Anders here. Can we assume that it's okay to be a bit late with the imported implementation towards brokers and if required, come with updates during the pilot project using the full PJ message set due to imported software deployment plans? Yeah, so we understand that your business, everyone's gonna have different business operations and we won't be able to dictate like specifically about which date you would require to have the software development. The pilot, when it starts, if you are not able to commit filing certificates for all your products, that is okay. You could begin if a subset of products, they have the certificate data available and you're able to file. You could choose to start with the full message set as Anders suggested here or you could continue to use the product register using the UI, for example. We're trying to be as flexible as possible. We understand that you have competing priorities and we're gonna work with you throughout this whole process. I see there is a question, a hand raised by Xu Shuang. Please go ahead and speak. Hi, this is Xu Shuang from REI. We are the importer and does this e-filing pilot include in FTZ entries? Yes, FTZs would be included. We do need to provide some guidance regarding FTZs but the idea is that once a product exits the FTZs, that's the point where you provide the certificate data. So here's my second question. So can we just file the regular entry and what I'm trying to say is can we not participate in the pilot for our FTZ? Yeah, so you could begin with your regular entries at the time and when you're prepared to file the FTZs, you could do so at a later date during the pilot. We hope, we plan to have that material available to you by the end of the summer. And so we hope that you could test it during the pilot but again, it comes down to you how you choose to file the data and for which products. And the pilot is for six months and so if by the first month the pilot you're not prepared for every product, that's okay, you could do it later. And once the pilot finishes, it will turn into a voluntary process until final rulemaking. So you could continue to practice and file the certificates for different products. Okay, I have another question. So we have some kids bicycles. So do we have to file a CPC or GCC for kids bicycle? A children's bicycle would require a CPC. The rule is that any product for a child 12 years and younger would require a CPC. Okay, because on your e-filing HTSCLE flagging, it doesn't specify for the HTSCLE, it does not specify that GCC is required. So if we have a kids bicycle that's under the same HTSCLE, we only have to file a GCC, but I mean CPC. And we don't have to file a GCC, right? That may have been an oversight on that list and it depends on the product you're bringing. If it's a bicycle for a child, then it's a CPC. If it's an adult bicycle, then it's a GCC. Okay, that's clear, thank you. So I have a question here from Guido. Will importers be required to provide a full list of HTSCLE codes or only provide a few HTSCLE codes for some chosen products for the purposes of the beta pilot? So you won't necessarily need to provide us a list of the HTSCLE codes you're using. We will actually be able to obtain that data because when you file, we already know your IOR number that you're gonna use in the pilot. So we're gonna use that to keep track of the message sets that were submitted and CBP will send us every message set that was submitted. And with that, we will have the HTSCLE code. So in short, you're not gonna provide us that list but we will know which HTSCLE codes you're using. Okay, I have a question from Sandy. In case we assign the lab to enter data for the product registry, do we share the same amount, the same account login? That's a great question. So no, in short. So you, Sandy, as the importer will have a business account that is solely created for your company. You would be like the business account holder and you provide access to other people in your company to be business account owners as well. Then you would be able to invite a lab or another third party to enter data on your behalf into what we're calling collections. So you could have as many collections as you want to manage and store your certificate data and to keep things organized. By having multiple collections, you'll be able to assign different third parties to different collections. So you could protect CBI if necessary just keep your products organized. So at that point, your lab, the official at your lab will receive an email invitation. They will go into the registry, create their own account and they will have access to your collection to enter that data but only to that collection where you provide the permission. That lab, if they're working with another importer, could also receive a permission to the other importer's collection. They will, that lab will maintain their own account login and when they log in, they will see both collections and be able to access both and enter managed data in both. However, those collections don't communicate with each other. They won't be able to copy data for one collection the other because those are data for different importers. So that's how the sandbox is created. The importer has the main account. The data that's entered on their behalf is there. They have the ownership and legal responsibility. Therefore, they will tightly manage that data and provide permissions to whomever they would like. Does anyone else have any more questions? A follow-up question from Sandy. Can the lab join the pilot program for testing? So the lab could work with you. So you are the imported participant. You could bring in any third party that you find necessary to assist you on the project. We will just only ask that you inform us that they are participating with you. Well, I still have time in this hour for any of your questions. Okay, so a question from Vijay. Does this apply for children's goods only? No, so eFiling applies to products that require certificates and there are general use products intended for adults that require certificates. One example that was given earlier were bicycles. Adult bicycles need to be tested and certified. They, I mean, the requirements for them is a little bit different from children's bicycles, but at the end of the day, they also need to be tested and certified. If you go through CPSC's website, you could find the list of all products that are regulated by CPSC. So therefore require certificates. And just kind of a note, any time you be here, me or anyone from CPSC say regulated products, these are products that we have an active rule of regulation or standard that applies to the product. And therefore those products require testing and certification. There are other products that are within CPSG's jurisdiction, but we do not regulate. So therefore no certificate is required. And then I have a second question from Stuart. Can you provide more detail on who have access to public repository and as a follow-up, who can amend the info? Only the person filed initially anyone with access. So Stuart, I not go into too much detail because the registry is pretty advanced and I could probably spend an hour talking about it. And we will have training in the future, in the near future regarding this registry and give you, provide you with a walk-through on how to use it. And so you as the importer will be the business account holder, I assume that you're the importer. So you of course will have access to populate data into the registry. In your account, you would have multiple collections if you'd like to organize and manage your certificate data. If you would like a third party to enter the data on your behalf, then you would provide them access to your account. They will receive an email invitation and by filing that invitation, they will create their own account login and then see your collection and be able to submit data on your behalf. So there'll be multiple options or multiple types of permissions. So you could have, provide like edit permissions so that third party could essentially do everything that you can. You could also limit the permissions on who can certify the data or not because it's as the importer, you are ultimately responsible but you could delegate that certifying permission to a third party or you can maintain it yourself. So someone could file the data on your behalf, submit the data into the registry on your behalf and then you have to review it and certify. We'll go into more details of these permissions later, one of our later training sessions. And then you also have options to provide someone a permission to view. They will just see what data is available but they can't access. So when it comes to amending the info, it really comes out and it has access. So the business account holder, so people in your company will have full access, full control of everything essentially. However, third parties who have the provide permissions to it depends on what permissions you provide them. And we also created the system in such a way where you're able to submit some data and then save that certificate. We're kind of foreseeing that in some cases, one individual has perhaps a lab information, the product description immediately available and wants to submit it. And then a second person goes in to submit like the manufacturer information, for example. So there are multiple means to access it. I think once you see it and once you get to play around with it, you click with you. Is there one-to-one assistance available to help with submitting this data? That's a question from Aharon. Yes, so CPSC staff will be available to help you. And we're happy to have like one-to-one meetings with you and your broker if you have specific particular questions regarding your data. Are there any more questions? I don't see any more hands raised, nor do I see any more questions in the chat. I'm just gonna finish this meeting. And if you have any questions, hop on into the chat or turn off your mic and speak up. So thank you once again for joining us in today's meeting. This is the first of many meetings. You'll have a lot of us and you'll hear more of me in the future. We're very excited to have you participating with us. We do believe that working with industry on a project such like this is just gonna end in a huge success. So we're very excited to have you participating. And on that note, I will end the meeting. I'll stay on to the end, but thank you and have a good rest of your day. Thank you for the presentation, Arthur. Have a great day. Welcome. Thank you, bye. Thank you, bye. Thank you, bye-bye. Thank you. I'll go ahead and end the meeting. Bye, everybody.