Not surprisingly, in view of the chaotic and rushed introduction of Section 103 tracking labels guidance by the CPSC, major retailers have been forced to implement their own versions of tracking labels in the hope that their work will suffice. And you thought only weather forecasters made a living by guessing!
I have attached Walmart's tracking labels guidance for your review (1, 2 and 3). It doesn't match the CPSC guidance, which is no surprise in large part because Walmart was able to publish theirs in May, while the CPSC could only squeeze out some guidance in late July. The Walmart guidance tries to be friendly and unthreatening, noting that these guidelines only apply if you haven't developed your own approach. That said, their guidance is very specific and provides conclusions that do not correlate to the CPSC outcomes. In Walmart's defense, they are not well-known to be CPSC mind readers, so some variance from the later guidance could be anticipated. If you are selling to Walmart, who's guidance will you follow? And if you happen to have other customers who also have their own plans of action? Can you picture a fair bit of completely wasted and pointless activity by manufacturers trying to align every customers' requirements?
I thought the Walmart decision trees were particularly amusing. They each look like a beginning decision tree for how to build the Space Shuttle. I see a decision tree like that and I try to find something else to do. . . . Walmart also provides some interesting photo illustrations of tracking label cases, with the "right" decisions indicated. I am not so sure I agree with all their calls. No matter, it's all clear as a bell now with the CPSC's guidance, right?
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I see just some of the money, time and effort that has been spent by retailers and manufacturers on trying to comply with CPSIA. I shudder to think of what this law has already cost the economy. And that, only a fraction, of what is yet to come. If only I could believe that the end result is increased safety.
You're aware, aren't you, that these are not requirements be carried by Wal-Mart, but rather requirements for Wal-Mart branded products (Great Value, etc.). In this case, isn't Wal-Mart the "manufacturer," and they can set whatever standards they feel comfortable with and take the risk accordingly?
Certainly Wal-Mart can and will set whatever standards it wants. Yes, these standards are for its proprietary items (private label), however the rules apply to its manufacturing partners. The law on tracking labels applies to all products equally but when companies start changing the rules (making them tougher or somehow different), problems result. My point is that the law has not created uniform rules in the marketplace. There is not only a lot of variety in retailer requirements that often have nothing to do with the new legal requirements (or safety considerations) but also a lot of confusion on requirements. Some retailers actually seem to be competing to comply the most vigorously, almost like they are trying to win some sort of virtue contest. Since I believe this requirement is a big waste of time and money, I have little sympathy for those companies that seek for some inexplicable reason to expand or modify the requirements.
At least Walmart took the time to help their suppliers. Some retailers say "comply" and never try to help the suppliers understand "how".
This tracking label blog is a waste of your time, and frankly I have wasted my time reading it. Get a life.
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