Distributor to Supplier: Is this Product OK for Children?
- A separate GCC is required for every production run—indicating the manufacture date. Be sure that that the GCC you receive is specific to the product you've received.
- Ask your supplier to confirm that the product you are receiving is being manufactured in the same factory where the tested product was manufactured, that there have been no changes in the design or bill of materials since the test and that the tested product was produced from the same raw materials as your production pieces. If not, you should insist that your production pieces be tested.
- It is best to communicate directly with your supplier's compliance department or the supplier's person responsible for compliance. Product safety laws are complicated and evolving. The people most likely to know the most are those who deal with compliance every day. My recommendation is to deal with suppliers who are knowledgeable about these product safety and compliance matters and who provide you with direct phone and email access to get your questions answered.
- This article applies specifically to the children's product provisions in the Consumer Product Safety Improvement Act (CPSIA). There are other federal product safety regulations and there are several state regulations. PPAI has developed an excellent tool called Turbo Test to help distributors and suppliers determine the regulations that may apply to a wide range of products in the industry and PPAI also has a relationship with a third party laboratory that is available to advise members. Also, there are many attorneys whose practices include a specialty in product safety legislation.