Notes from China

Over the past week I have traveled to Hong Kong and to Guangzhou,China to talk with representatives of the apparel and toy industry about CPSIA implementation issues. Because of the complexity of this law, it is so important that we make ourselves available to those who are actually making consumer products for the US market to educate them about their safety obligations under the law. In no particular order, here are some of the things I heard:
• I heard consistent complaints about the very short comment periods being made available to those who want to have input into our various regulations. The observation was made more than once that perhaps the agency did not really welcome public comment because the comments periods where typically too short for thoughtful input. I want you to know I have been pushing for longer comment periods because your insights are both welcome and needed.
• Another theme I heard was the need for more flexibility to be built into the testing requirements. Many believe they are spending money with no real safety gain when the funds could be targeted to the areas of actual risk.
• For industries with rapidly changing inventory, such as the fashion industry, requiring random statistical sampling for all changes in product lines will result in enormous costs. There is a great deal of concern about how our soon-to-be-published proposed rule on periodic testing will impact this industry.
• There is great hope that component testing will offer some solutions to decrease costs and increase efficiencies. However, I got conflicting messages about whether this will actually result in developing a market for third party tested component parts. In some instances, this is already happening. However, I heard complaints that, for certain commodity-type products, such as wire, there is no real way for component testing to be helpful.
• With respect to phthalates testing, the agency’s change in test methods has resulted in significantly increased costs and our list of products with either a high or low risk of phthalates has caused confusion.
• A constant theme was the need for greater harmonization. The cost of testing and complying with various standards around the world is a burden on the manufacturing process and impacting consumer choice.
• More than one company told of sending the same product for testing at various accredited labs only to get different test results back, as well as conflicting advice on what testing is required.
Talking directly to those who are trying to implement this law is an invaluable experience. I continue to welcome your thoughts as we try to roll out new requirements imposed by the law. With safety as our constant goal, we are trying to get it right but we need your input to make that happen.

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2 Responses to “Notes from China”


  1. 1 Sarah Natividad April 4, 2010 at 8:12 pm

    It really won’t matter a whole lot whether you require statistically random sampling or not.

    First off, as I’ve explained on my blog a while back, you can’t get 100% certainty of compliance with any testing regime, even flat-out testing everything, whether or not you dress that regime up in fancy math symbols or make a random choice of samples (even if a totally random choice were possible).

    Second (and more importantly since we obviously can’t get Congress to learn some math), smaller firms are eventually just going to give up and quit trying to comply and instead rely on not getting caught.

  2. 2 Vivian Zabel March 31, 2010 at 11:22 am

    I’m so afraid that the CPSIA is another law forced on us that will never change, just impose a high cost on us. That seems to be the rule of thumb for anything coming out of Washington any more.

    I’m rather discouraged.


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