Tuesday, February 24 was the second day of the ICPHSO Annual Meeting and Training Symposium in Orlando, Florida. The Crowell team was on the ground throughout the day, and the sessions did not disappoint. From cybersecurity standards for IoT devices and the European Union’s (EU) sweeping new compliance obligations — the General Product Safety Regulation (GPSR), the Ecodesign for Sustainable Products Regulation (ESPR), and Digital Product Passports — to U.S. Consumer Product Safety Commission (CPSC) eFiling deadlines and the challenge of age-grading products in a social media landscape, the recurring question was the same: how do regulators, companies, and standards bodies stay ahead of a marketplace that never stops moving?

With that backdrop in mind, here are some highlights from the day’s sessions and key takeaways for product safety professionals today.

CPSC eFiling: Clock Is Ticking

This panel examined the CPSC’s landmark mandatory eFiling rule, which requires importers to electronically submit Children’s Product Certificates and General Certificates of Conformity through U.S. Customs and Border Protection’s (CBP) ACE system at the time of entry, with an effective date of July 8, 2026. Structured around practical guidance, the session was designed to help EU brands and foreign manufacturers understand their compliance obligations, avoid supply chain disruptions and penalties, and build documentation workflows that met the new regulatory standard.

Here is what product safety professionals need to know:

• The data challenges are significant. Gathering, validating, and submitting the detailed information required under the new mandate requires careful coordination across the supply chain. Companies should be actively working now on practical solutions for:
  • How to identify and handle exempt adult apparel.
  • Aligning lab procedures for data collection to support eFiling workflows.
  • Managing component testing and relevant data collection.
  • Establishing testing rules for product groupings, multi-facility manufacturing, and additional colorways.
  • Auditing the accuracy of lab data transmissions.
• Retailers need to assess their product portfolios — now. If that work has not started, it should. Key priorities include identifying which products fall under applicable HTS codes and distinguishing between private label and national brand imports.
• Do not wait for certainty to act. Even as the future of implementation and enforcement remains fluid, the CPSC’s 2026 Operating Plan makes the CPSC’s priorities unmistakably clear: surveillance of unsafe imports — particularly low-value e-commerce shipments — remains a top enforcement focus, with AI being deployed to identify high-risk shipments before they reach consumers. The mandatory eFiling requirement sits squarely within that enforcement framework.

The bottom line: the window to prepare is narrowing. Companies that treat eFiling compliance as an operational priority today will be far better positioned to avoid supply chain disruptions and penalty exposure tomorrow.

Product Liability and Product Regulation: Comparing the Systems That Hold Products Accountable

This panel explored the dual legal pressures shaping product safety in the U.S., comparing the role of government regulation and enforcement against the outsized impact of product liability litigation — a fragmented, state-by-state system whose consequences can rival or exceed those of regulatory action. Featuring compliance professionals with both litigation and regulatory backgrounds, the session used real-world scenarios to examine how these two systems interact, compete, and sometimes converge, while also interrogating whether the severity of U.S. litigation translates into greater consumer safety.

Here is what product safety professionals need to know:

• Recalls are stressful, and stressful situations create bad documents. When a recall is underway, the pressure to move fast can lead to sloppy, poorly worded, or prematurely conclusive internal communications. Every document created during a recall or investigation is potentially discoverable in follow-on litigation. Discipline in documentation is not a legal formality — it is a strategic necessity.
• A litigation complaint is also a CPSC reporting trigger. If your company receives a product liability complaint, that alone may give rise to reporting obligations under the Consumer Product Safety Act (CPSA). If you do not report, the plaintiffs’ bar may do it for you — or the CPSC may come to you directly, based on its own product litigation monitoring efforts. Waiting is rarely the safer option.
• How you engage with the CPSC matters — from the very beginning. The atmosphere surrounding a recall shapes the entire trajectory of the investigation that follows. This includes early decisions, such as whether a stop sale is necessary before a formal report is made. Getting the tone, timing, and approach right from the outset can make a meaningful difference in how the process unfolds.

The takeaway from this session was straightforward: regulatory and litigation risk do not operate in separate lanes. Companies that plan for both — and treat every recall as a potential legal proceeding from day one — will be far better prepared when both systems come knocking at once.

Innovation in Product Information Sharing: Advancing International Convergence and Supply Chain Simplification 

This panel discussed how emerging technologies — particularly Digital Product Passports and AI — can drive international regulatory convergence by creating a single, unified source of product information that satisfies compliance requirements across multiple jurisdictions simultaneously. The session showcased practical applications for complex global supply chains, addressing real-world challenges such as multi-language support, data accessibility, and the protection of sensitive manufacturing data, while demonstrating how these digital solutions can improve product traceability, consumer safety, and compliance efficiency for manufacturers and regulators alike.

Here is what product safety professionals should take away:

• Digital Product Passports reduce friction and improve efficiency. By consolidating product information into one accessible digital record, passports make it easier to share data with regulators, supply chain partners, and consumers — reducing administrative burden and unlocking both economic and safety benefits for manufacturers operating across multiple jurisdictions. Further discussion on Johan Keetelaar’s paper on Digital Passports is available publicly here.
• Regulators need to keep pace. Technology is moving faster than the legal frameworks designed to govern it. For digital passports to reach their full potential, regulators must adapt — not just by updating the rules, but also by rethinking how they monitor markets and leverage the traceability and product information now available to them. Countries like Chile are already looking to peer jurisdictions to identify best practices and build stronger relationships with suppliers.
• Consumers become active participants in product safety. Digital passports enable real-time, two-way communication between products and the people who use them. Consumers can access product information, instructions, and warnings instantly — and share their product experiences in return. This kind of information sharing is poised to become a meaningful channel for delivering safety information, warnings, and recall notices.
• QR codes are a practical gateway. Simple and accessible, QR codes offer an immediate bridge between physical products and their digital records — allowing consumers to verify certifications, access instructions and warnings, and even submit a claim directly if a product causes harm.

The bottom line: the Digital Product Passport is not a distant regulatory concept — it is a practical tool that is already reshaping how manufacturers, regulators, and consumers interact with product information. Companies that invest in these capabilities now will be better poised to meet the compliance demands of tomorrow’s global marketplace.

From Orlando to the Office: Carrying the Conversation Forward

The conversations at ICPHSO this year reflect a product safety community that is engaged, clear-eyed, and ready to meet the challenges ahead. We look forward to sharing more from the symposium — and to continuing these conversations with our clients and colleagues in the weeks to come.

Stay tuned for more recaps from the ICPHSO Annual Meeting & Training Symposium.