Monday, September 14, 2009

CPSIA - Oh, Joy! Tracking Labels Fun

It's starting. Today featured two interesting "New Era" experiences for us. First, one of our larger customers sent us THEIR requirements for CPSIA tracking labels. Mind you, we have never had a safety issue with this account in the last 20 years. Their tracking label standards and expectations do not match our understanding of the law as implemented by the CPSC. We think we know what's required. It doesn't matter. This is going to cost us money, and will happen again and again with our larger customers, all of whom are competing with their different requirements for the title as the most compliant company on the planet. Regulatory Compliance Exuberance, I just LOVE it!

And then we had to redesign a product we sell in a Point of Purchase Display. Yes, the fact that we make selling our products easier for our dealers means that we have to endure more stringent labeling requirements. In this particular case, I will stake my reputation on the prediction that this particular product will never be recalled, but it doesn't matter under a brainless law. We must make the "co-hort" information "ascertainable" to consumers, no matter that it will be useless to them. I have spend real, scarce green dollars to do this, and will mar the appearance of our successful product (which is optimal now). The initial cost will be $8,000 out of pocket, plus the cost to our company of having a less appealing product. All for something that will NEVER be recalled. How satisfying. . . .

The tracking labels provision was inserted into the CPSIA by none other than consumer advocate Barack Obama. Thanks, Prez!


Michael said...

We enjoy the same level of good customer relations as you do Rick. This same issue ('use our label' layout) will also rear its head on GCC's, it already rears its head on product summary listings for compliance, and the actual timeline of requirements and their implementation by the CPSC be damned, full compliance right now. Our experience has been that you can give the Customer a marked up PDF of the actual CPSC document and it still isn't sufficient to overcome fear. Today, a very large account has dropped 4 products because their XRF Scanner program says there may be 'lead in paint issues' - even though the CPSC has stated that XRF technology will not correctly screen for lead in paint. We've provided that document (issued by the CPSC about 8/17) at least three times in the last three weeks to no avail. The products have been tested, we have provided the testing documents, none of that matters. All of this effort using their spreadsheets. Managing the customer's fear, along with maintaining testing, GCC's and labeling will easily consume one business day a year per SKU, easily.

I'll be buying a lottery ticket in the morning.

Allvira said...

Its exactly good point. I am satisfied with Michael, actually handling a customer is not a play of children. As I think, its a trick able? LOL!!!
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