Full PGA or Reference PGA? What the Importer Prepares and What the Broker Files

Synthetic training examples are clearly labeled. Official instructions and responsible professional decisions remain controlling.

Narration

Full PGA and Reference PGA are two different ways certificate information can support the CPSC message set in the ACE entry workflow. They are not two names for the same handoff. The safest operational step is to confirm the path with the broker or authorized filer before the importer assembles the package.

Use a simple decision map. If the entry will carry the seven required certificate data elements, the preparation resembles Full PGA. If the entry will reference an already certified Product Registry record, the handoff needs the three current certificate identifiers. The responsible parties must determine the appropriate path for the product and entry; this lesson does not make that legal or customs decision.

For Full PGA, CPSC describes seven required product certificate data elements: Product ID, citation codes, manufacture date, manufacture place, product test date, testing laboratory, and point of contact. The importer prepares reviewed facts and supporting evidence. The broker or authorized filer uses the applicable data in the separate ACE PGA Message Set transmission.

For Reference PGA, the importer first enters and certifies the product certificate data in the CPSC Product Registry. The handoff to the broker uses the Certifier ID, Product ID, and Version ID. Those identifiers must point to the current certified record. An import that is still awaiting certification is not represented as a certified record.

Consider one simulated product: a desk lamp identified as model LMP-220. Under a Full PGA workflow, the broker may need the reviewed seven-element data package for the entry. Under a Reference PGA workflow, the broker needs the three identifiers for the applicable certified Registry version. The product is the same, but the handoff objects are different.

The Product Registry does not automatically transmit information to ACE. CPSC describes it as a stand-alone central repository. After a product certificate is entered and certified, the importer must communicate the three certificate identifiers to the broker so the ACE Reference PGA Message Set can accurately point to that record. A Registry confirmation is therefore not the broker’s ACE filing.

CertifyPreflight can organize source-linked evidence, expose missing or conflicting candidate values, support a customer-authorized Product Registry action, and preserve current identifiers for the broker handoff. Certification remains role-gated and separately authorized. CertifyPreflight does not determine the customs path, replace the broker, or transmit the broker’s ACE entry.

If you are unsure which preparation route fits your situation, run the free fit check at CertifyPreflight dot com slash fit check. Confirm the final path with the broker or authorized filer and use current official CPSC guidance. Neither path is presented here as universally required, cheaper, faster, or guaranteed to clear a shipment.

Meaningful visual descriptions

Official sources

• CPSC eFiling Frequently Asked Questions
• CPSC Product Registry
• CPSC Product Registry User Guide V3
• CPSC eFiling Resources for Brokers

Sources reviewed October 8, 2026.