Update for children’s products manufacturers
I thought of amending the first post I wrote about this but reasoned too few would see it.
Background: if you make products for children aged 12 and under, you’re required to comply with a law known as CPSIA -it’s been so onerous that F-I has a separate category set up for it. If you didn’t know about it, you have a lot of reading to do. This isn’t something to sweep under the rug because penalties are substantive and small companies are not exempt nor protected by the aura of good intentions.
Last week I’d mentioned you needed to register before the end of the year to qualify for certain testing exemptions. [Again note this is a testing exemption, not a compliance exemption. It matters because testing was the thing that was going to put a lot of people out of business (it actually did before the law was amended). ] I have it on good authority, specifically CPSC ombudsman Neal Cohen, who called me today to say there is no deadline. Yes, no deadline. This is good news. Now obviously you need to have your exemption in hand before selling anything but the deadline is not 12/31/11 and Mr. Cohen agrees the communication was problematic.
Several people (me included) have reported that their registration was declined because the url of their email address did not match their company’s name. Said parties were directed to send detailed information about their business on official letterhead in order to affect approval. This created an additional problem because many people don’t have letterhead owing to the predominance of electronic correspondence. Mr Cohen amends the email you may have received saying that letterhead isn’t needed. He sent these directions that you are to follow if your registration was declined:
Please submit a letter with your signature to include the following information. You can scan and email it, or send it through the US mail or fax it to the number below:
And a statement with the following:
I certify that (name of your company) is a manufacturer, importer or private labeler of a consumer product or other substance over which the CPSC has jurisdiction and that (name of the person) is authorized to receive and comment on Reports on behalf of (name of your company).
You may direct your response to the U.S Consumer Product Safety Commission, National Injury Information Clearinghouse, Small Business Account Verification:
By email: firstname.lastname@example.org
By Facsimile: (855) 221-6466
By Mail: 4330 East West Hwy., Room 820, ATTN: Small Business Account Verification, Bethesda, MD 20814.
So there we go! No more drama over deadlines. No more drama over mis-matched email addresses and no more drama over letterhead.
Be well. Go forth and prosper!