Published on March 5, 2014
REGULATORY ENFORCEMENT: A CONVERSATION PANEL DISCUSSION ICPHSO ORLANDO, FL FEBRUARY 27, 2014 VIEWS EXPRESSED IN THIS PRESENTATION ARE THOSE OF THE STAFF AND DO NOT NECESSARILY REPRESENT THE VIEWS OF THE COMMISSION.
FINDING CPSC LETTERS OF ADVICE • Identify applicable regulatory requirements for your product • Based on: • Product/product class • Intended age audience & consumer use patterns • Product’s material composition 15 USC §2063; 16 CFR §1107.20
FINDING CPSC LETTERS OF ADVICE • Identify one (or more) CPSC-accepted laboratories to conduct testing for identified regulatory requirements. • Certify in a Children’s Product Certificate (CPC) based on passing test results. • Provide CPC to retailers and distributors and, upon request, to CPSC or Customs (CBP). 15 USC §2063; 16 CFR §1107.20; 16 CFR 1110
CPSC LETTERS OF ADVICE 1,775 Violations From Oct. 2012 through January 17, 2014
CPSC LETTERS OF ADVICE • Voluntary; 16 CFR Part 1109 • If a finished product manufacturer purchases a component from a supplier who voluntarily tests its product (e.g., a paint supplier), that manufacturer must “exercise due care” to rely upon the component part certificate or component part test results in drafting its own Children’s Product Certificate. • The concept of due care is flexible, and it will vary depending upon the circumstances and the industry in question.
CPSC LETTERS OF ADVICE LOA Table: Action Requested by Office of Compliance: Consumer Level Recall Retail Level Recall Distributor Level Recall Stop Sale and Correct Future Production Correct Future Production
CPSC LETTERS OF ADVICE Import: Actions Requested by CPSC at Ports of Entry Seizure & Destruction (Destruction by CBP; Requested by CPSC) Conditionally Release & Recondition (CPSC Office of Import Surveillance and Office of Compliance & Field Operations; Release under Bond) Conditionally Release For Destruction (CPSC Office of Import Surveillance and Office of Compliance & Field Operations; Release under Bond) Export Unconditional Release
RESOURCES Twitter Desktop Reference Guide @CPSCSmallBiz www.cpsc.gov/desktopguide Slideshare CPSIA Resources www.cpsc.gov/GettingStarted Downloadable Presentations www.SlideShare.net/USCPSC Email list signup www.cpsc.gov/email
THANK YOU : Neal S. Cohen Small Business Ombudsman email@example.com : Mary Toro Director, Div. of Regulatory Enforcement Office of Compliance firstname.lastname@example.org Questions?
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