Trade Asks CPSC to Allow Brand Names on Infant/Toddler Registration Forms
In August 2011, the Consumer Product Safety Commission issued a proposed rule to clarify and correct its 2010 final rule on durable infant or toddler product consumer registration form requirements.1 Comments from the trade indicate that they support the changes but suggest that CPSC allow more recognizable “brand names” to be used on the cards.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
(See ITT’s Online Archives 11080821 for summary of the August 2011 proposed rule which was issued at the request of certain manufacturers and testing labs.)
Agree Proposed Changes Would Simplify & Clarify Registration Form Info
The trade generally agreed with the proposed amendments, stating they would:
- Simplify the provisions for the format and text of registration forms;
- Clarify the required font size for the forms;
- Clarify that consumers should return the bottom part of the form only;
- Omit the manufacturer’s name requirement on the back bottom of the form;
- Identify a third party processing the forms;
- Clarify the location where registration information is to be maintained; and
- Correct the purpose statement text requirement.
Suggest Allowing Brand Names Instead of Mnfr/Importer on Registration Cards
They suggested however, allowing companies some additional latitude to list a third-party vendor (who will process the registration cards) or a “brand name” in lieu of the manufacturer’s name. They state this is because consumers may be more inclined to fill out a card identified by a more recognizable processor or “brand name” than an unknown manufacturer or importer.
1In 2010, the CPSC implemented a final rule required by the Consumer Product Safety Improvement Act of 2008 (CPSIA), to require manufacturers of durable infant or toddler products to: (1) provide with each product a postage-paid consumer registration form; (2) keep records of consumers who register such products; and (3) permanently mark each such product with the manufacturer’s name and contact information, model name, etc. The rule also specified the text and format for the registration form and establishes requirements for electronic registration. (See ITT's Online Archives 09122915 for summary of the final rule.)