China Toy Fair


CPSC Filing Requirements Could Add $18.7 Million Burden on Industry

Proposed changes to the Consumer Product Safety Commission’s (CPSC) certificate of compliance requirements could add complexities and significantly alter the way most companies manage their logistics for inbound freight to the U.S., according to the Toy Industry Association (TIA). The changes could more than double compliance costs for children’s product companies—from an approximate $15 million annual spent to comply with current certification requirements to nearly $34 million annually. Comments on the proposal are due to the CPSC by July 29.

Under the amended rule, companies that import regulated finished products manufactured outside of the U.S. would be required to file product certificates electronically with the 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.

TIA will be submitting comments to the CPSC by the deadline regarding the content requirements of the certificate, the economic impact of the certification rule, the logistics of electronic certification, and more. Members may contact TIA’s Rebecca Mond with any feedback to be included in the submitted comments, or to receive additional information about the rule’s impact. Comments on behalf of individual companies may be submitted directly to the CPSC at www.regulations.gov (docket number CPSC-2013-0017).