CPSIA Update: More on the Tracking Label Requirement

By May 14, 2009Regulations

CPSC Commissioner Nancy Nord, acting chairman, and Commissioner Thomas Moore have released their statements on the NAM-CPSC’s Coalition petition for a stay of enforcement on the tracking label requirement. (For explanation of the issue, see this post.) Nord voted for a stay, Moore against.

As Nord explains in her statement, tracking labels on consumer products are supposed to expedite product recalls. But…

The tracking label requirements of the Act have the potential to be especially burdensome given the long lead times many companies need to implement such requirements. Unfortunately, the law does not give us appropriate lead time nor does it give us flexibility to impose the requirements by product class and prioritize in an order based on importance. For example, with more regulatory flexibility, I would argue that we first turn our attention to high value products with long useful lives and a history of recall issues. Applying lessons learned, we could then determine how the tracking label requirement should be applied to additional products.

Too sensible.

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