CPSIA Update: Physically Impossible or Financially Disastrous

By July 9, 2009Regulations

When the House Energy and Commerce Committee holds a hearing this month on the implementation of the Consumer Product Safety Improvmeent Act, a major topic must be the Aug. 14 effective date of the CPSIA’s product labeling requirements. Industry has been provided NO official guidance from the CPSC on implementing the law.

From the National Bulk Vending Association, “NBVA Goes To Capitol Hill Seeking Relief From Product Labeling Burden In CPSIA“:

WASHINGTON — Bulk vending leaders traveled to Capitol Hill on June 26 to meet with members of Congress, legislative directors and committee staffers to press for relief from onerous Section 103 in the Consumer Product Safety Improvement Act of 2008. With the clock ticking toward the Aug.14 enactment of the new law that would require tracking labels on all toys sold in the U.S, officials from the National Bulk Vendors Association made their case for an exclusionary ruling in the vending channel.

If enacted in its current form, Section 103 would require manufacturers of bulk vending merchandise to label each toy with such information as source of the product, date of manufacture, and batch or run numbers. The association’s position is that such labeling is physically impossible given the amount of usable surface area typically available on the majority of bulk-vended toys. Even if such labeling could be accomplished by way of some yet unidentified technology, the costs would very likely prove prohibitively high for the low-cost vendible toys.

In short, the bulk vending industry, which has complied with all rulings of the Consumer Product Safety Commission in the past, now finds itself in the unenviable position in which compliance is either physically impossible or financially disastrous.

The National Association of Manufacturers and the NAM CPSC Coalition last week filed a renewed petition for a one-year stay of enforcement of the product labeling requirement.

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