With the economy going south the Consumer Product Safety Improvement Act of 2008 could not have come at a worse time for small businesses that manufacture or import children’s products.
The real question on the minds of most small businesses involved with children’s products is – will the new chair of the Consumer Product Safety Commission, Inez Tenenbaum, bring relief to small business or will she simply be the enforcer of the new Consumer Product Safety Improvement Act (CPSIA) of 2008 and force most out of business because of the high cost of legal compliance?
The first thing Ms. Tenenbaum will need to do is clarify the agency’s position regarding testing, labeling, tracking and it’s current ban on the sale of existing inventories. According to the CPSIA of 2008 all children’s products will have to be tested for safety by an independent testing lab certified by the CPSC. Warning Labels will now need to be on the product, packaging, Internet sites and catalogs and comply with a specific layout, type, language, color and placement. Tracking must be on each product and show source of product, date manufactured and batch or run number.
If Ms. Tenenbaum simply chooses to be the enforcer of the CPSIA of 2008, most small children’s importers and manufacturers will be forced out of business because they are barely surviving due to current recession and the high cost of legal compliance will, likely, be the final nail in the coffin.
Those choosing to continue to import and manufacture children’s products will not have the luxury of easing into the market place. They will need deep pockets to support their efforts and a marketing plan that will have be aggressive so they can sell enough products to offset the increased investment cost.
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