Writing at the Aftermarket Business website, D.C. attorney Paul Laurenza talks about another provision of the Consumer Product Safety Improvement Act that will have a sweeping impact on business — the certification requirements. And one industry that’s bound to be hit is automotive supplies
Applying to both importers and domestic manufacturers, CPSIA section 102 requires that all product shipments carry outlined certification information that must be furnished to U.S. distributors and retailers upon delivery. The certificates require various information, including identification of all CPSC-administered standards applicable to the product, testing entities and contact information.When first enacted in August 2008, the provision was generally viewed as applying only to children’s products. However, the U.S. Consumer Product Safety Commission (CPSC) later announced that the section would be applied to any product that falls under a similar CPSC ban, standard, rule or regulation.
Through public comments, manufacturers, distributors and retailers pushed back on the determination, which applied the section 102 requirements to many non-children-related items, including automotive chemical specialty products. These products already must meet stringent regulations under the Federal Hazardous Substances Act (FHSA) and Poison Prevention Packaging Act (PPPA) for distribution.
So yet another unintended consequence: A burdensome, expensive and duplicative system of certification for products with no connection to children.
For the CPSC’s materials on Section 102, start here.
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