Consumer Product/Customs and Regulatory Compliance

Cognitive Solutions actively tracks pending legislation and executive regulation to provide prescient advice concerning likely, future requirements. Current legislation will impact all businesses producing and selling consumer products. Current highlights of the Consumer Product Safety Commission (CPSC) Reform Act include for example:

  • 3rd party testing (of consumer products) in foreign countries
  • Prohibits imports without certification (after the product has been tested by an “independent” lab)
  • Requires notification of any issue and corrective action (affecting consumer health or safety such as recalls) in order to publicize on the CPSC website
  • Disclosure of the identities of all subcontractors and any threat (and requiring packaging that informs the consumer)
  • Exports of banned products under control (so they don’t get back into the US market)
  • Reports of any false certifications (in foreign countries but to be published on a CPSC public website)
  • Recognized laboratories (again in foreign/producer countries)
  • Mandatory Standards (for safety (e.g. lead content), testing-as above and labeling/identification
  • Greater sanctions, penalties and forfeitures (significantly higher and including asset forfeiture-the most potent Federal penalties)
  • Bonds for performance/guarantees (lesser for compliant firms/more for those that are not or cannot prove that they are not)

This legislation will result in increased cooperation with the States, which means that manufacturers have to address 50 enforcer’s competing to be first to find and publicize that something is wrong. Additionally, whistleblower protection and more Internet publicity probably mean more individual allegations which will erode brand value and take time to correct, refute and dismiss.

Cognitive Solutions capacity to meet these and similar requirements are:

  • Labeling and tracking to preclude problems in the first place and enable manufacturers to respond more quickly and confidently to concerns
  • Track the product back to origin meeting requirements to identify subcontractors
  • Benefits to consumer product health and safety, but also to compliance (customs) and facilitation, supply chain reliability and security