Wednesday, June 2, 2010

CPSIA - Thank You Sir, Please Give Me Another . . . .

Today I was assaulted with the news that our company had just received a bill for more than $4,000 to test one of our older items as required by one of our major retail clients. This particular retailers requires that we test every shipment to them using their lab, their prescribed assortment of tests and their pricing - at our expense. There are no exceptions to this rule and no negotiations are tolerated. It's said to be "a cost of doing business", and we are supposed to take this cost into account when we price our products to them.

This item has been tested I don't know how many times. Many times in many forms. Every test was a pass. This latest $4,000 test told us NOTHING we didn't already know. Had we done the tests ourselves using our primary test lab, we would have spent a fraction of the $4,000 we were required to pay by our retailer client. The product is no safer with this latest test. Most of the money (60%) went to phthalates testing.

Although there is nothing about this test that does NOT irritate me, proving the absence of the six banned phthalates is BY FAR the most offensive. We use materials that do not contain the banned phthalates. This is something that our supply chain management is supposed to address. Even more to the point, since these chemicals have been banned for almost two years for use in toys (for better or worse), they are largely absent from the supply chain without our doing anything at all. Yet, the geniuses who wrote the CPSIA require that we test each product, over and over, to prove they're not there. Phthalates cannot spontaneously generate themselves - they are an ADDITIVE. Having jacked up penalties to the sky and hit several retailers with highly-publicized irrational and vindictive penalties, the CPSC has created a caustic environment in which testing is not negotiable with large retailers. Hence, we must prove again and again that the phthalates that weren't there, aren't there. This costs BIG MONEY. It accomplished absolutely nothing.

And the $4,000? We were theoretically supposed to charge the customer for the testing in our product pricing, but in fact, in most cases, we must absorb the cost. That's the real world. So we make $4,000 less in profit. We have $4,000 less to invest in our business, $4,000 less to pay health care costs, $4,000 less to pay for innovative product development, $4,000 less to pay bonuses. No one is safer, either. And this is good for all of us? A good way to run a country?

And where did the $4,000 go? To China. The lab which our client requires we use is a public company, and the chosen lab is located in China. Notwithstanding the lab's low operating costs, the prices we pay for this testing are full boat, un-discounted, nosebleed pricing. They simply vacuum up as much of our money as they are allowed, and your wonderful Democrat Congress shrieks with delight.

We're so safe now . . . .

I can only hope that the jobs of the Democrats who are keeping us in this CPSIA hell aren't as safe come November. That seems to be the only recourse we have left.


Anonymous said...

Oh goody, more money to China. You guys may as well shut down your juvenile product operations, everyone in the US should. Another few years and no one in the US will be able to afford toys anyway since the majority of our jobs have been outsourced to China.
Viva the Chinese! US, next 3rd world country. I am now buying tents and bottled water for my grandchildren.

Notechaser said...

I doubt the composition of Congress will make a difference (especially at this point), all politicians will avoid the wrath of the fearloaders.

Anonymous said...

I have been reading/following Rick's blog posts for many months now, and I want to congratulate Rick for hitting the nail dead center, direct hit, one-time and through the wood, with this post. There is not a better example to prove how ridiculous this crap is! Anyone interested in starting a testing facility? I could use a mansion and a yacht - thanks Elmer Fudd!
Keep up the good work. Unfortunately many of these facts are brutally obvious, but thanks for putting them in print for hopefully the idiot left can read...or maybe to have someone who comprehends English read to them.

Anonymous said...

at this point it would actually cost more to purchase/produce products containing phthalates and lead.