In August the Consumer Poduct Safety Commission (CPSC) passed the Consumer Products Safety Improvement Act which has caused quite a bit of commotion is some circles. Initially the legislation appears to simply strengthen the safety regulations for children’s products in reaction to the many recent toy recalls. That is only part of what the law does. I will explain the little bit that I understand but more in depth information can be found here.
Every manufacturer, importer or private labeler of a product that is subject to a product safety rule or similar rule, ban, standard, or regulation, must now furnish a General Conformity Certificate (FAQ and sample in pdf) to the downstream distributor or retailer of the product, included with each shipment. The General Conformity Certificate requires nine specific pieces of information:
- Identification of the product covered by the certificate
- Specification of each CPSC product safety regulation being certified
- Identification of the foreign or domestic manufacturer certifying compliance of the product.
- Identification of the U.S. Importer certifying compliance of the product (if any)
- Identification of private labeler certifying compliance of the product (if any)
- Contact information for the individual maintaining the test results
- Date and place where this product was manufactured
- Date and place where this product was tested for compliance with the regulations cited above.
- Identification of of any third-party laboratory on whose testing the certificate depends.
It is not exactly clear when the requirements will go into effect or exactly who in the supply chain needs to comply. We do know that the punishent for noncompliance is extremely stiff; penalties include imprisonment for up to 5 years and fines up to $15,000,000. This is serious. The testing to comply is costly and could effect profit for many businesses in a major way.
I don’t want anyone to be alarmed, I just want everyone to be informed. This is a link to more information on Fashion-Incubator. If anyone has more information, please pass it along.
