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Back To Basics: Safety Requirements for Children’s Promotion

Safety and reporting is everyone's responsibility.

8/21/2015 | Jeff Jacobs, The Brand Protector

When it comes to the safety requirements of children’s promotional products, sometimes, it's a good idea to break it down to the basics and look at the fundamentals. That can often bring a whole different perspective to the table, and that's what we'll try to do here today.

The Consumer Product Safety Commission, with the 2008 Consumer Product Safety Improvement Act, authorized a variety of new regulations and testing requirements for products primarily intended for children under the age of 12, aka children's promotional products. Wherever you are in the supply chain, everyone has some responsibility for making sure the testing under these regulations is done, and documented, properly.

Reasons to Test and Document

When it comes to the myriad of reasons to test and document the safety of children's promotional productions, a variety of opinions abound. However, if the reasons to test and document were a simple multiple choice question, they would look like this:

1) To protect the ultimate end-user- consumers

2) To protect your company, and yourself

3) Because it's the law

4) All of the Above

If you chose "All of the Above," then our trip back to basics is working – so far.

But why is everyone – the suppliers importing blank goods, as well as the distributors decorating those same goods – responsible for the safety requirements associated with promotional products intended for children? That's an easy answer. It’s because the CPSC has made it everyone's responsibility to REPORT goods that violate federal consumer product safety laws and regulations that have a defect that could cause a substantial product hazard, or which create an unreasonable risk of serious injury or death.

So, that's pretty clear. Safety and reporting is everyone's responsibility, no matter where you fall in the supply chain. But, let's dig further: who is ultimately RESPONSIBLE for the compliance of children's product?

First, let's consider intended usage. A "children’s product" is defined as any item intended primarily for children 12 years of age or younger. Children's products have important safety regulations covering substances used in manufacturing, like lead, and other potential hazards, like small parts, that can present a choking hazard. Toys have even more special requirements.

The definition of just what is a "children’s product" is very important in our industry. If, for example, a decoration is added to a blank piece of drinkware, and just the decoration alone appeals to a child under 12, the decoration just transformed the product from one defined as a "general use product" into a "children’s product."  Even though the change in artwork may appear to you to be an almost miniscule change, it has important implications for consumer safety and, along with that, a company's compliance with federal laws.

Ultimately, that transformation of the product dictates the responsible party when it comes to meeting regulations. If you are a supplier importing finished goods, the responsibility lies wholly with you. If you are a distributor and manage only the decoration that transforms a blank general use item into a children's product, then you have responsibility for meeting the regulations regarding the materials used to decorate that product. You can learn more at: www.cpsc.gov/childrensproduct.

There's good reason the CPSC expects that everyone in the supply chain bear responsibility to report non-compliant products. There's just too much at risk. By the time you consider choking hazards, flammability, a concentration of heavy metals like lead in manufacturing, or phthalates in items like bibs and toys, it's just good sense to have everyone on watch. What do you think about this issue? I'd love to hear your thoughts.

Jeff Jacobs has been an expert in building brands and brand stewardship for more than 30 years. He’s a staunch advocate of consumer product safety and has a deep passion and belief regarding the issues surrounding compliance and corporate social responsibility. He is the executive director of Quality Certification Alliance, the industry’s only non-profit dedicated to helping suppliers provide safe and compliant products. When he's not working, you can find him traveling the world with his lovely wife, working as a volunteer Guardian ad Litem, or sometimes even enjoying a cigar at his favorite local cigar shop. Follow Jeff on Twitter, or reach out to him at jeff@qcalliance.org.

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