In 2013, the CPSC announced a proposed change to the regulations governing certificates of compliance. The proposal would create expansive new burdens on manufacturers, distributors and retailers and impose significant costs without clear justification. Currently, importers of consumer products are required to provide proof via a “certificate of compliance” that a product or component part meets applicable standards and testing requirements. Last year, the CPSC issued a proposed rule that would impose significant burdens on manufacturers and the importers of consumer products. Through formal comments, many associations requested that the rule be withdrawn and that the CPSC work with stakeholders on needed changes to the existing regulations.
SGIA signed a letter urging the Consumer Product Safety Commission to conduct a workshop of interested stakeholders before finalizing its proposal for “at entry” filing of product compliance certificates in the Proposed Amendments to 16 CFR Part 1110 (the 1110 Rule), 78 Fed. Reg. 28080 (May 13, 2013). Moving from the current on demand system to a required at entry filing represents a significant change to current supply chain operations and will have a major adverse impact on businesses’ operations.
“Substantial information technology investment will be necessary from all parties in order to implement “at entry” filing. Because of these significant impacts, we believe that before the agency moves forward with its proposal for “at entry” filing of compliance certificates, it is critical to engage with CBP, stakeholders and technical experts on several important implementation issues. We urge the CPSC to establish a stakeholder forum (or Industry Workshop) to discuss the issues associated with such a move forward.
SGIA will continue to work on this issue and keep the industry updated as to progress or changes regarding this important industry issue.
For more information on this subject, contact Marci Kinter at govtaffairs@sgia.org.