05/28/2026
42 days to CPSC eFiling.
If you run DTF on imported decorated, licensed, or kids' apparel, the program your OEM or your distribution partner walked into your shop with should already be doing three things for you right now.
If it isn't, that's a question worth asking your partner this week — not in July.
1. Documentation should ship with the consumable.
GCC, CPC where applicable, SDS, third-party test record, and a named records custodian — landing with the order, not three days later, not on the next order. If you are still emailing your ink or film supplier asking for the SDS, the program in your shop isn't producing the documentation it should be.
2. The consumable side of your vendor list should be small and named.
If your ink is from one vendor, your film from another, your powder from a third, your cleaners from a fourth, and nobody owns the documentation across that surface — you have a multi-vendor problem your customer's compliance team is going to surface in 42 days. A documented closed-system stack collapses that to one row on the vendor list with one named records custodian.
3. Your customers' broker should already be running it.
The CPSC voluntary stage is live. Brokers who are operating under the PGA Message Set are running 16 CFR 1110 six-data-element entries through ACE today. If your end-customer's broker has not validated the documented side yet, that is the call to make this month, not next month.
The mandate hits July 8 and the rule is the rule — but the partners doing the work right are already producing the proof. If your Catalyst partner / OEM / distributor isn't, that's the conversation.
For the framework in one place: nucoatinc.com/pages/grand-slam