The NAM issued a statement Thursday on the CPSC’s vote to not grant a stay of enforcement from the tracking label requirements of the Consumer Product Safety Improvement Act, “NAM Says CPSC Decision Denying State of Labeling Rule Fosters Confusion and Uncertainty.” From Rosario Palmieri, NAM Vice President for Infrastructure, Legal & Regulatory Policy:
Changes in product processes, including changes in labeling requirements for packaging and products, usually take at least a year in many sectors in order to assure smooth execution. This process must begin in the design phase of the product, well before production takes place. The new tracking label provision will necessitate legal reviews, compliance clearance, and training of supply chain partners. Many companies are already ordering, planning and costing production of goods that will be made in the fall of this year or later, meaning they must guess how the new labeling requirement will be implemented. If they guess wrong, they will have to scramble to rework labeling and packaging at significant cost.
Already, confusion and uncertainty about the CPSIA’s provisions have become a nightmare for many manufacturers. Businesses just want clear guidance, flexibility and sufficient time to implement the new rules. If the CPSC cannot implement the law in a reasonable way, then Congress must amend it.
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