Critical Dates Regarding the New Consumer Product Safety Improvement Act

November 12th is the First in a Series of Critical Dates Regarding the New Consumer Product Safety Improvement Act (CPSIA)

SGMA Members are being alerted now to act with all due speed. Non-compliance with the Act may put your company at risk for monetary and possible criminal violations.

SGMA and our Legal Task Force are in communication with the CPSC and attend all Commission meetings and hearings that pertain to issues affecting you. The following are some of the most pressing deadlines and issues that you need to be aware of and address immediately:

• On November 12, 2008 all products subject to the CPSIA bans and standards as well as subject to any similar rule, ban, standard or regulation under any other Act enforced by the Commission, must be self-certified with a General Conformity Certification.

• The General Conformity Certificate must be based on a “test of each product or upon a reasonable testing program.”

• Certificates must accompany each product or shipment of products covered by the same certificate. And, a copy of the certificate must be furnished to each and every distributor and retailer of the product.

• If a General Conformity Certificate does not accompany each imported product or product shipment then all of your products “shall be refused admission.”Products refused admission can be destroyed!

• The Commission warned that each company needs to go through a detailed analysis of its products to determine whether your products are subject to the CPSIA’s new self-certification requirements.

It is imperative for your company to do a thorough product analysis. Do not delay! Call SGMA or our Legal Task Force members for advice immediately.

This ALERT is merely a tip of the iceberg with respect to what SGMA members must do to comply with the CPSIA and its rolling dates over the next 2-3 years. To keep you well-informed SGMA’s Legal Task Force will have another conference call on October 27, 2008 to update you on the most pressing deadlines and issues involving the CPSIA and the up-to-date thinking of the Commission. Details regarding the call will be emailed shortly.

SGMA members can visit www.sgma.com for further CPSC details and to access a CPSC Improvement Act Recap PowerPoint Presentation that summarizes the issues that were discussed during the September 11th CPSC Conference Call that SGMA hosted. Members can also contact Chris Strong, SGMA’s Director of Business Development, at 202.349.9413 or cstrong@sgma.com.



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