Industry News

CPSC to Revise Proposed Component Rule

February 4, 2011


In May 2010, the Consumer Product Safety Commission (CPSC) issued a proposed rule regarding requirements for testing component parts of consumer products to demonstrate compliance with CPSC rules and bans when obtaining a General Conformity (GC) Certificate or a Children’s Product Certificate. In a January 31, 2011 staff memo to the Commissioners, CPSC staff indicated that the proposed rule would reduce the burden of the testing and certification requirements set forth in the Consumer Product Safety Improvement Act of 2008 (CPSIA). The CPSC staff argued that the proposed rule would provide significant advantages for manufacturers, especially if their suppliers of component parts choose to perform component testing.

Comments submitted to CPSC reflect industry concerns as to whether the proposed rule will actually provide the intended relief. Industry comments indicated concerns that in the proposed rule, tracing requirements are too onerous and costly, record keeping is excessive and burdensome, and suppliers have little incentive to participate. CPSC staff are reviewing comments and writing responses. They have said that they will submit a draft final rule to the Commission “in the fiscal year 2011.”

For further information, contact a Barnes/Richardson attorney.