In a June 19 statement, Commissioner Nancy Nord last week reported the Consumer Product Safety Commission was soliciting comments on implementing Section 104 of the Consumer Product Safety Improvement Act requiring registration cards and permanent labels for durable infant and toddler products. The CPSIA will also require tracking labels for all children’s products, so there are issues of duplication involved as well as simple practicality: Is it possible to actually do the labeling?
Nord’s letter raises a new issue we hadn’t seen among the many other CPSIA requirements, to wit, businesses must have an online presence in order to do sell these products. From her statement:
What issues are raised by the mandatory on-line registration requirement, especially with respect to small business? The law requires that manufacturers of durable infant and toddler products have an on-line presence in order to sell their products. This is perhaps one of the first examples of Congress forcing technology on a company that sells products to the public. While I recognize that many small business people are innovators in their use of technology, I am also concerned that there may be smaller, regional companies or artisans who make these products but who do not have a web presence and therefore may not be able easily to set up a mechanism for managing product registrations on-line in addition to off-line registrations. Nevertheless, the law seems to require this result. We have tried to address this by requiring an email address (rather than a web site) which may or may not be adequate to meet the requirements of the law.
Did you know that? If you sell infant products, you MUST be online. Whether that’s a good idea or not — and it seems like an obvious business necessity — a mandatory Internet presence represents a fundamental shift in technological policymaking, worthy of extensive Congressional deliberation and public input.
We don’t recall any of that kind of debate.
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