Back in 2008, The Consumer Product Safety Commission authorized a variety of new rules and testing requirements specifically related to children’s promotional products. When it comes to the safety requirements of products intended for children as end-users, it’s always a good idea to break it down to the basics and look at the fundamentals.
Reasons to Test and Document
There are many reasons to test and document the safety of children’s promotional products, and if you were to put them into a multiple choice format, they would look like this:
A) To protect the ultimate end-user consumers
B) To protect your company and yourself
C) Because it’s the law
D) All of the above
In case you weren’t absolutely certain, the correct answer to the above question is D. But, more importantly, do you know that everyone–from the suppliers importing blank goods to the distributors finishing those same goods—are responsible for the safety requirements of those products? Well, that is very much the case. This is because the CPSC has made it everyone’s responsibility to REPORT goods that violate federal consumer product safety regulations.
So, we’ve established that safety and reporting is everyone’s responsibility, but let’s dig a little deeper: who is ultimately RESPONSIBLE for the compliance of children’s products?
When it comes to compliance, it’s the transformation of the product that dictates the responsible party. If you are a supplier importing finished goods, the responsibility lies wholly with you. If you are a distributor and manage only the decoration that transforms a blank item into a children’s product—a painted image of a children’s character on a cup, for example—then you are responsible. If this is a topic that impacts your business, you can learn more about this at: www.cpsc.gov/childrensproduct.
There’s good reason the CPSC has an expectation that everyone in the supply chain bear the responsibility to report non-compliant products. By the time you consider choking hazards, flammability, the use of heavy metals in manufacturing, or phthalates in items like bibs and toys, it just makes sense to involve everyone when it comes to the issue of compliance. What do you think about this issue of responsibility and compliance? I’d love to hear your thoughts.
If you’d like to learn more on this topic, please hop over and check out my column at the Promo Corner Blog.