The workshop will allow CPSC to clarify issues and understand stakeholders’ concerns related to the proposed amendments to the Certification of Compliance Rule – which would require companies that import products manufactured outside of the U.S. to file general conformity certifications (or children’s product certifications) electronically with U.S. Customs and Border Protection (CBP) prior to importation, in conjunction with other customs entry documents. Additionally, certifications would have to be identified prominently on the finished product, shipping carton, or invoice with a unique identifier and be accessible online without password protection.
According to the CPSC, the certificates are intended to be uploaded as data elements and searchable online so that the agency can use them for import surveillance and targeting purposes. The ultimate goal would be to incorporate the data elements from certificates into RAM (risk assessment methodology) analysis to enable CPSC to make better risk-based decisions for clearance and inspections.
As reported in May 2013, CPSC’s proposed changes to the rule would pose a significant financial and logistical burden to many businesses without improving product safety. Since the certification rule was first introduced in 2008, companies have functioned on an “on demand” model, whereby certificates are available to the CPSC on request. For the past six years, businesses have figured out ways to incorporate the requirements into their daily operations – from quality control to importation procedures.
“As amended, the regulation would considerably alter the way most companies manage their logistics for inbound freight to the U.S. – the changes could more than double compliance costs for children’s product companies, from an approximate $15 million annually spent to comply with current certification requirements to nearly $34 million annually,” said Ed Desmond, TIA executive vice president of external affairs.
The CPSC has reopened the docket associated with the proposed changes so that stakeholders may submit written comments related to the workshop through October 31st. TIA, which submitted comments on the proposed changes last year, will be submitting additional comments on behalf of its members. Any TIA member that wishes to provide input to be included in the Association’s comments is invited to contact Autumn Moore (amoore@toyassociation.org) by August 15th. Comments on behalf of individual companies may be submitted directly to the CPSC at www.regulations.gov (Docket No. CPSC-2013-0017).
The deadline to register as a workshop presenter is August 8th; the deadline to register as workshop attendee is September 5th. The workshop will take place on September 18th between 9 a.m. and 4 p.m. at CPSC headquarters in Bethesda, MD.
Additional information about the workshop is available in the Draft Federal Register Notice.
0-3 years 
