eFileIQ Terms of Service

These Terms of Service (the “Terms”) form a binding agreement between Corporate Systems Associates, Inc. (“Corporate Systems Associates,” “we,” “us,” or “our”) and you, together with the company on whose behalf you act (“you” or “Customer”). They govern your access to and use of the eFileIQ website, application, and related services (collectively, the “Service”). By creating an account, accepting an invitation to join an account, or otherwise using the Service, you accept these Terms and confirm that you have authority to bind your company to them. If you do not accept these Terms, do not use the Service.

1. The Service

eFileIQ ingests the laboratory test reports and related documents you provide, assists you in preparing Children’s Product Certificates (CPCs), General Certificates of Conformity (GCCs), and CPSC disclaim filings (Type A intended-use and Type B non-children’s-product), and other supporting records. It submits those filings to the CPSC Product Registry using the API credentials your company supplies, and can forward filed-certificate reference information to a customs broker or other recipient you designate.

The Service does not file with U.S. Customs and Border Protection (CBP), does not submit CBP Partner Government Agency (PGA) message sets, and is not a customs entry filer. Any customs entry, ACE filing, or PGA submission remains the responsibility of you or your customs broker.

The Service is a workflow and automation tool. All filings and transmissions are initiated at your instruction and made under your company’s own CPSC account. We act only as your service provider. We do not certify products, and we are not the importer of record, the certifier, or the filer of record for any product.

2. Eligibility and business use

The Service is intended solely for business use by companies that are subject to CPSC certification requirements and by their authorized personnel. You must be at least 18 years of age to use the Service. The Service is not directed to or offered to individual consumers, and any consumer-protection rights that apply only to consumer transactions do not apply to your use of the Service.

3. Your responsibilities

Review before filing. Information that the Service extracts from your documents is provided for your review and may be incomplete or incorrect. You alone are responsible for reviewing and approving all content before it is filed, and for the accuracy, completeness, and legality of everything submitted under your company’s CPSC account. Submitting a filing without first reviewing it is done entirely at your own risk and constitutes a breach of these Terms.

Automated approval rules. Certain green-rated submissions may be marked for automated approval based on rules you or your administrators configure in the Service. Any such rules are set and enabled by you, and you remain solely responsible for their outcomes, including any filings made under those rules.

Authorization. You confirm that you are authorized to connect and use the CPSC credentials you provide, to designate any customs broker or other data recipient, and to act on behalf of the company you represent. You are responsible for the activity of every user on your company’s account and for safeguarding all passwords, tokens, and multi-factor authentication devices. You will notify us promptly if you suspect any unauthorized access to your account.

Acceptable use. You will not misuse the Service, attempt to access data belonging to another company, reverse engineer, scrape, resell, or sublicense the Service, probe or interfere with its security or integrity, introduce malicious code, or use the Service for any unlawful purpose.

Your records. You are responsible for retaining your own copies of the source documents you provide. The Service is not a system of record and is not an archival or backup service.

4. Not legal or compliance advice

The Service does not provide legal, regulatory, or compliance advice, and no output of the Service — including extracted data, suggested rule citations, AI-generated summaries, filing status, or answers from any built-in assistant feature — constitutes advice or any assurance of compliance. You remain solely responsible for determining which products require certification, which rules and citations apply, whether the underlying testing is sufficient, whether any testing laboratory is CPSC-accredited for the citations claimed, and whether any filing satisfies your legal obligations.

eFileIQ and Corporate Systems Associates, Inc. are independent and are not affiliated with, endorsed by, or acting on behalf of the CPSC, U.S. Customs and Border Protection, or any other government agency.

5. Your data; license to us

You retain all rights in the data and documents you submit to the Service (“Customer Data”). You grant us a limited, non-exclusive license to host, process, and transmit Customer Data solely to provide the Service as described in these Terms, in our Privacy Policy, and in accordance with your instructions. You represent that you hold all rights necessary to submit Customer Data to the Service, including any personal information contained in laboratory test reports (such as lab technician names, signatories, and contact information).

Your CPSC credentials are stored encrypted in a hardware-backed key store, are used solely to submit filings you have approved for your company, and are permanently deleted from the Service within thirty (30) days after termination of your subscription or your written request, whichever is earlier.

Data residency. We currently process and store Customer Data in Microsoft Azure regions located in the United States. We will provide reasonable prior notice before materially changing the primary storage region.

AI processing. To provide the Service, Customer Data (including uploaded test reports and their extracted contents) is transmitted to third-party AI providers, currently Anthropic PBC via Anthropic’s Claude API, for extraction, classification, and assistant features. Anthropic does not use Customer Data submitted through its API to train its models. AI-generated outputs (including extracted fields, suggested citations, and assistant answers) are provisional and require your review as set out in Section 3.

Subprocessors. We use a limited set of subprocessors to operate the Service, listed on our Subprocessors page. We remain responsible for their compliance with these Terms. We will provide reasonable notice before adding a new subprocessor that materially changes how Customer Data is processed.

Security incidents. If we become aware of a security incident that affects the confidentiality or integrity of your Customer Data, we will notify the account’s administrative contact without undue delay and provide reasonably available information about the incident, its impact, and any remediation steps.

6. Our intellectual property

We own the Service and all components of it, including its software, user interface, design, extraction and parsing logic, and documentation. These Terms grant you only a limited, non-exclusive, non-transferable right to use the Service for your company’s internal business purposes during your subscription term. No other rights are granted, whether by implication or otherwise. Any feedback or suggestions you provide may be used by us freely and without any obligation to you.

7. Availability and beta features

We aim to keep the Service available and accurate, but interruptions, scheduled maintenance, and errors can occur. Unless your company has entered into a signed agreement containing an express service-level (uptime) commitment, no uptime commitment applies. Some parts of the Service may be identified as beta, preview, or evaluation features (including AI assistant features) and are provided without any warranty or commitment of any kind.

Filing outcomes also depend on the CPSC’s systems, broker systems, email and network providers, and other third parties outside our control, and we are not responsible for their availability, errors, or changes. See our Security page for information on how the Service is protected.

Trial and evaluation access. Trial or evaluation access to the Service is provided AS-IS, may be modified, suspended, or terminated at any time, and is subject to Sections 9 and 10 without regard to any fee thresholds.

8. Fees

If your use of the Service is subject to fees, those fees will be set out in a separate agreement or order form with your company. Except as stated in that agreement, fees are non-refundable. Unless otherwise stated in an order form, subscriptions automatically renew for successive terms equal in length to the initial term. You may cancel renewal through the Service, or by written notice to us, at least thirty (30) days before the end of the then-current term.

We will provide at least thirty (30) days’ notice before any change to pricing, and any such change will take effect at the start of your next renewal term. We may suspend access to the Service for non-payment following notice.

9. Disclaimer of warranties

10. Limitation of liability

11. Indemnification

You will defend, indemnify, and hold harmless Corporate Systems Associates, Inc. and its owners, officers, employees, and agents from and against any claims, fines, penalties, losses, liabilities, and expenses (including reasonable attorneys’ fees) arising out of or relating to: (a) Customer Data or the products to which it relates; (b) any filings made under your company’s CPSC account; (c) your breach of these Terms or violation of any law; or (d) your designation of a customs broker or any other recipient of your data.

12. Termination and data export

You may stop using the Service at any time and may request deletion of your company’s data. For a non-material breach that is capable of being cured, we will give you notice and a reasonable opportunity of at least ten (10) days to cure before suspending or terminating your access. We may suspend or terminate access immediately in the event of a material breach of these Terms, suspected unauthorized use or a security threat, non-payment following notice, or where reasonably necessary to protect the Service or other customers, and otherwise on reasonable notice.

Export on request. For a period of thirty (30) days after termination or cancellation, on your written request we will make reasonable efforts to make your Customer Data (including submissions, generated certificates, and audit history) available for export in a commonly used format. After that period, we may delete Customer Data in the ordinary course of operations. CPSC credentials are handled as described in Section 5.

Sections 4 through 6 and 9 through 15 survive any termination of these Terms.

13. Governing law; arbitration; class-action waiver

These Terms are governed by the laws of the State of Connecticut, USA, without regard to its conflict-of-laws rules. Any dispute arising out of or relating to these Terms or the Service that the parties are unable to resolve informally will be finally resolved by binding arbitration seated in Hartford, Connecticut, USA, administered by the American Arbitration Association under its Commercial Arbitration Rules, before a single arbitrator, with judgment on the award enforceable in any court of competent jurisdiction.

Either party may instead bring an individual claim in a small-claims court, and either party may seek injunctive relief in the state or federal courts located in Hartford County, Connecticut for misuse of the Service, infringement of intellectual property, or breach of confidentiality.

14. Force majeure

We will not be liable for any delay or failure in performance caused by events beyond our reasonable control, including acts of government, CPSC or other third-party system outages, internet or infrastructure failures, labor disputes, and natural disasters.

15. General

These Terms, together with our Privacy Policy and any signed order form (which will control in the event of a conflict), constitute the entire agreement between the parties regarding the Service. If any provision of these Terms is held to be unenforceable, it will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will remain in full force and effect. Our failure to enforce any provision is not a waiver of it. You may not assign these Terms without our prior written consent; we may assign these Terms in connection with a merger, acquisition, reorganization, or sale of assets. There are no third-party beneficiaries to these Terms. Notices to us must be sent through our contact page; notices to you may be sent to the email address associated with your account.

16. Changes to these Terms

We may update these Terms from time to time. If we make material changes, we will update this page and the “Last updated” date above. Your continued use of the Service after the changes take effect constitutes your acceptance of the updated Terms.