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Monday January 14, 2019

Year Phase-In for Recall Cards Too Long, Say Consumer Groups

CPSC should shorten to six months a proposed phase-in related to recall registration cards, consumer groups wrote in late December. Their comment targeted contoured changing pads, which the agency would clarify are subject to the rules at 16 CFR 1130.


The agency had said (PSL, 10/15/18) that a year for makers and sellers of such products to get into compliance was consistent with the time given in 2009 when the registration-card rule originally became effective. However, the consumer groups asserted:

"Many manufacturers of contoured changing pads make other durable infant or toddler products and already have a registration program in place. For others, a registration program should not take longer than six months to implement since product registration program technology has advanced significantly since 2009."

The groups otherwise were favorable towards the draft updates, especially the addition of product classes not mentioned in the original rules. They wrote:

"Section 104 of the CPSIA was never intended to be a definitive list of products to be covered by mandatory standards and product registration requirements. Rather, it listed products addressed by voluntary standards at the time and included other products generally considered to be durable infant or toddler products. We supported the CPSC's previous addition of additional product categories at the time the rule was written, and we strongly support the CPSC's continual addition of new products to the rule as they are developed and put into the marketplace. It would be inconsistent with statute and not make sense to neglect protecting children simply because new product categories are now available."

The groups were Consumer Federation of America, Consumer Reports, Kids in Danger, Public Citizen, and U.S. PIRG. The letter was not available among posted comments (PSL, 1/7/19), likely due to the government shutdown. The activity involved the product registration cards required under the 2008 CPSIA aimed at improving recall rates.


Most of the changes would involve definitions or related clarifications. Those would go into effect after just 30 days. The consumer groups agreed with that timing.