Infant/Toddler Durable Goods Registration Requirements
In the June 29, 2009 Federal Register, the Consumer Product Safety Commission published a notice which implements a provision in the Consumer Product Safety Improvement Act that requires registration by manufacturers of durable infant or toddler products and includes importers as manufacturers. Retailers are also covered but only if they are the importer. CPSC wants comments about who should be subject to the registration requirement. CPSC also wants comments on the "practical and economic consequences" of any such decision. How will importers mandate the inclusion of the registration card by their suppliers? Who bears that cost? Who maintains the database of registrations which is also required. Should that burden be put on foreign manufacturers? How would they implement and maintain the data? How would CPSC access it in the case of an enforcement effort? Should the burden be on distributors? private labelers?
Examples of durable infant products include children's folding chairs, changing tables, bouncers, infant bath tubs, bed rails, infant slings, changing tables, cribs and cradles (and other products under ASTM subcommittee (F15.18) such as toddler beds, play yards and bassinets), plus gates and other enclosures for confining children.
The statutory definition is somewhat uncertain, and many products may last three or more years, so CPSC is soliciting comments on what products should be subject to the registration requirement and whether a definitive listing of those products should be itemized and published.
The registration involves both a postage prepaid consumer registration form and Internet registration for each product; maintenance of a record of the contact information of consumers who register their products with the manufacturer; and permanently placing the manufacturer's name and contact information, model name and number, and the date of manufacture on each durable infant or toddler product. All such details must be treated as confidential and may only be used for product recall or safety alert purposes.
For more details such as the form and content of the registration card and record keeping mandates, see http://www.cpsc.gov/businfo/frnotices/fr09/durable.pdf. Comments are due by September 14, 2009.
