Think This Can't Happen to You? The Reality of CPSIA
We have all heard about the Consumer Product Safety Improvement Act (CPSIA). And up to now, as distributors, we have been relatively insulated to the developing changes that suppliers have had to follow closely and adapt to be compliant.
That is all ending now.
Recently, an account executive in our company placed an order for imprinted key tags. The order arrived, but along with the client's logo and website there were a series of numbers printed under where the imprint was located. They didn't know what these numbers were. Upon checking with the supplier, it was discovered that this is part of their CPSIA labeling effort. These numbers are a tracking number that is now printed on products that are considered for use by children.
A tracking number will now be imprinted on about 475 of this supplier's products. And at the moment you may not know where the numbers are being printed as it depends on which product you buy. Apparently they are working on a system to give this information to distributors via their website or in future catalogs.
To me this is problematic. If a client's imprint is going to be changed to include these numbers, notification on the website and in a catalog is not going to cut it. I want a phone call before the order is printed at all. And what are the consequences of placing the numbers next to the client's imprint? I'm guessing a canceled order in many cases.
In this case the client was not very happy. Can you blame them? The tracking number was printed right next to their website and it looked terrible. This tracking information has nothing to do with California Prop 65 (a separate issue) but is a number that needs to be included on products that could be used by children. The supplier appears to be following CPSIA federal guidelines by including it.
How many other manufacturers may be doing this? If these numbers are placed with the client's logo, without clear notification, how many orders will be rejected?
I would have to assume that any proofs to be approved prior to production would need to show these numbers. At that point, what happens when the client says "no" to their imprint being changed?
Vendors who start arbitrarily putting these CPSIA numbers on products will run into problems. Most clients are not going to appreciate their brand image being compromised with these numbers.
Below is the response from the supplier:
"In response to your inquiry regarding our compliance labeling efforts and I would like to address some of your questions. I'd like to apologize for any unexpected results our customer encountered as a result of out labeling efforts and completely understand your desire for more information regarding this matter. I have included our summary statement, which gives an overview of our position as well as a list of items that 'our company' has included in our CPSIA labeling effort.
"Basically, we need to include tracking information on all products that could be considered a children's product under the CPSIA mandate. We include that info on approximately 475 products, many of which lend themselves to being labeled less obtrusively than the item that you ordered for your customer (bags have stitched in labels for instance). There are a handful of products that require some fine tuning with regard to the placement of the tracking info—the key tag you ordered being one of them. Keep in mind that we had to institute this pretty rapidly which deprived us of the ability to fine tune the placement on each item—we are in the process of doing so and expect the tracking to become somewhat less obtrusive with each iteration.
"We are currently working towards more conveying the presence of tracking data to our customers via web, catalog, etc. so that you can advise your customers upfront. We firmly believe that the tracking data serves as an indicator of safety compliance and, placement on a very few products aside, should act as a selling point to the end user.
"Thank you for your feedback on this important effort. Our customer's suggestions will be taken into advisement as the process matures and evolves. Please let me know if you have additional suggestions or comments."
Well there you have it. The CPSIA changes have trickled down far enough that they are affecting distributors now. How will we respond? How will our clients respond? Our industry is facing many challenges, but this is going to be a big one. What perils lie ahead with CPSIA compliance? For me, I'm a bit stunned and frankly at a loss for words. And those who know me personally understand that I'm rarely at a loss for words.
PPAI Law has been working diligently on these issues, but now we are seeing the tangible impact of these legislated regulations. Feel free to comment below.
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