"Good morning. I'm calling from the Consumer Product Safety Commission."
- Suppliers can identify in their lines each product that could possibly be regarded by CPSC as a children's product, either because it innately fits the children's product definition or because it could become a children's product after being imprinted with a juvenile image. Then, if each of these products is manufactured and tested to CPSIA children's product standards, there is no issue. No one would have to evaluate art or worry about who a particular order is intended for because EVERY product complies.
- Another option is for suppliers to indicate in their catalogs, website, on ESP and SAGE, the specific products in their line that have been manufactured and tested as meeting CPSIA children's product standards. This option is a little more risky than option 1 because it requires more vigilance by everyone. If a distributor sends in a juvenile imprint order for one of the products that isn't marked as compliant and the supplier produces and ships it, then liability for everyone is still an issue. This option could work if distributors and suppliers have good communication and orders are clearly marked as "intended for children." eDistributors who receive orders over the Internet should require customers to answer a question about the intended use of the product—whether it is intended for young children—and the response should be included on the corresponding order to their supplier.
The one thing that none of us in the industry can afford to do is to ignore this issue or assume it's someone else's problem. This is a case where it really does take a village—everyone working together—supplier, distributor and end-buyer—so we make sure we all get it right. Who is the product intended for? Are children involved? If so, select only products which have been manufactured and tested as compliant with CPSIA standards. On that issue, there is no other option.