Protecting Your Client's Brand
The reusable grocery bag story is significant, but not unusual. For better or for worse, ever since millions of Chinese-made Barbie dolls were recalled for lead paint violations in what has become known as the "Summer of Recalls" (August 2007), the promotional products industry has had to deal with a new reality: the world of product safety, regulatory compliance and responsible sourcing.
So how do you embrace this new reality? Where do you get started and how do you make it part of your culture?
The first, and most important, step is education. Learn the basic product safety regulations and how they apply in our industry. The most comprehensive federal law is the Consumer Product Safety Improvement Act (CPSIA). It was enacted in August 2008 and imposes strict lead limits for all children's products, and additional requirements for toys. Much has been written about how to determine whether the product you're selling is regarded as a children's product. The distinction is not always clear and even experts sometimes disagree. Why does it matter? In addition to the lead restrictions, children's products require third-party testing, permanent tracking labels and certificates specifying when and where the product was manufactured and tested. For everyone's sake-your client's, your company's and the industry's-I recommend a simple rule of thumb: If the intended audience of a promotion includes children, protect everyone involved. Don't let yourself get sucked into a debate of whether the item is a children's product or a general-use product. For these promotions, play it safe and select products that have been produced and tested to CPSIA children's product standards.
One difficult challenge for the promotional products industry is that many products become children's products only after they are decorated. Most blank water bottles, for example, are considered "general use" and not subject to CPSIA. But if a water bottle is imprinted with a juvenile logo-such as a Winnie-the-Pooh type of character that appeals primarily to young children-it is transformed into a children's product and becomes subject to the entire suite of children's product rules. The same applies to string backpacks and a host of other similar products. Some suppliers will note on their websites the "child-friendly" products for which they have third-party testing. Other suppliers have CPSIA test reports for all of their products. Speak to your suppliers to learn each one's protocol for children's products. Complying with the law is a partnership and requires open communication between distributor and supplier. You should know which of your supplier's blank products are "children's product" compliant just as your supplier should be told when the intended audience for your promotion includes children. Make this a standard question you ask your clients for every order.