The CPSC is committed to continuously improving its import surveillance process so that it may help reduce unreasonable risk of injuries and deaths associated with consumer products and help the agency maintain its standing as a leader in consumer product safety in an ever-expanding global marketplace.
In support of continuous improvement, the Office of Import Surveillance (EXIS) has begun the phased implementation of electronic filing (eFiling) of Certificates of Compliance (see graphic below) to modernize the way import data are processed. This allows importers of regulated consumer products to easily store and eFile certain certificate data via CPSC’s Partner Government Agency (PGA) Message Set.
Benefits of the CPSC eFiling system include:
Fewer holds for compliant importers
Reduction in risk score for demonstrated compliance with CPSC’s requirements
Potentially shorter review periods
Increased CPSC focus on higher risk products
The CPSC understands the trade industry’s key role in helping develop a successful eFiling system. As such, a Beta Pilot effort will launch in the fall of 2023 to test IT systems. This pilot will include up to 50 volunteer participants who will be asked to provide feedback to inform the system design and final rulemaking for the full implementation of the eFiling system.
This public-private partnership is essential to the successful implementation of eFiling. We have exceeded our minimum threshold of 30 participants, but there is opportunity for more importers to participate in CPSC’s pilot.
The CPSC will continue to communicate regularly through future newsletters, fact sheets, and other information that will be available via their eFiling website (www.cpsc.gov/efiling), social media channels (@USCPSC), and their mailing list.
What is the IT-DAG?
The Information Technology-Data Advisory Group (IT-DAG) is an industry working group established to advise on the development of systems and processes for CPSC’s eFiling implementation. The IT-DAG kicked off in December 2022 and has made great progress in reviewing and providing valuable input to the CBP and Trade Automated Interface Requirements (CATAIR) and IT system requirements. Below is a summary of IT-DAG activities and results over the past several months:
Since December 2022, the IT-DAG has held six meetings where they reviewed and discussed the draft Beta Pilot CATAIR, the PGA Message Set, and the Product Registry.
CPSC has highlighted system business rules and demonstrated functionality that supports entry and management of certificate data in the Product Registry database.
Participants have been instrumental in providing valuable feedback to increase the efficiency and effectiveness of the system design and functionality.
The draft CATAIR has been updated, posted on www.cpsc.gov/efiling, and shared with IT-DAG participants as they begin their internal IT integration process, which will enable the electronic transmission of certificate data into the PGA Message Set.
The IT-DAG will continue to meet and review Product Registry functionality. The public is welcome to attend IT-DAG meetings as a non-member in listen-only mode or preview meeting summaries on the docket.
Regarding product safety, it is essential to stay ahead of the curve, and companies are often faced with the decision of how often to optimize their compliance program. Companies may ask themselves why they should change their existing program if it works. However, the real question should be: have I audited my program recently?
Not having a robust product safety compliance program can be risky if you are a business owner, executive, or Amazon Seller. Without proper policies in place, you could be putting your customers, employees, and brand reputation at risk. Consumers expect products to function correctly and meet specific safety standards in today’s market. Failing to comply with these standards can lead to costly lawsuits and damage your brand’s reputation. Amazon Sellers have seen increased compliance requests to approve a product, including instructions, warnings, labeling, and registration cards. Submitting these items will get your approval, but can you show proof of compliance to new retailers that need to see these policies and processes to ensure you deliver a safe product with each new shipment? More than having the documents is required, as all major retailers seek proof that you know what you are doing and have systems and training for your employees and contractors. Compare the Vendor qualification for Target in 2020 to today; you can now see the inclusion of a Quality Program Assessment and a Factory Assessment, and vendors are expected to employ best practices and well-documented manufacturing and GMP processes. Part of this results from being unable to visit your suppliers, but the other part is that good quality practices result in compliant products with fewer returns and chargebacks. But policies are part of the program as you also need staff training and process for record keeping. Your ideal compliance program will have all the components for identifying, capturing, and storing all company data, not just for Retailer qualification but in the event you would need to file a 15B report with the CPSC. Have you updated your program recently to identify and record where this data exists should you need to access it quickly? You also need a retention plan to back up this data should you migrate to a new system.
Adjust your Program to Changing Requirements
A product safety compliance program is essential for any business that produces or sells physical goods. The program should include policies that ensure all products meet mandatory requirements set by regulatory agencies, such as the Consumer Product Safety Commission (CPSC). It should also involve regular testing and documentation of each product’s performance and any necessary changes to meet the standard. Having proof of compliance can protect your business from liability claims if an injury occurs due to a faulty product. You should document all your steps, from the product’s design to delivery to the consumer. Your obligation does not stop with the sale. You also need an incident reporting policy and escalation program to satisfy the CPSC’s duty to report once you are notified of an incident while using your product. An incident can be reported to you via your customer service CRM system; it can come from a retailer or Amazon or be submitted to the Saferproducts.gov website. If you have a reportable incident and it is determined you need a recall, you should have a plan to prepare for this worst-case scenario. Amazon does not yet require a recall plan but has been discussing with the CPSC how they would handle recalls on their platform should one be needed.
Major retailers always ask about your recall plans, and having one can save you money on your product liability insurance. Today, many are now asking about how you are integrating ESG into your product safety program. ESG stands for “Environmental, Social, and Governance.” It can be described as a set of practices (policies, procedures, metrics, etc.) that organizations implement to limit negative or enhance positive impacts on the environment, society, and governance. Do you have the capability to add these items to your program in an integral way to meet these current and future requirements? Are you aware of new technology solutions that enable you to scale your program quickly and are more cost-effective than building or piecing together several systems?
We built Comply PRO+ for you to have an out-of-the-box platform to securely build your compliance program to show seller proof of compliance when entering new markets and sales channels. Post covid, more people are working remotely. Comply PRO+ is built on Amazon Web Services and is accessible anywhere there is an internet connection. We use 2-factor Authentication to secure your login and password so no unauthorized users are on your account. You still need to craft the policies and procedures to align with how you operate your business, but you do not need to spend time and money connecting several systems to capture the data you need for a robust program. If you haven’t done so in a while, audit your current program to see if it has the features you need to sell products in multiple sales channels and markets today and for what lies ahead tomorrow.
Compare these features to your current program…
1. Accessible anywhere
2. Secure platform with secure 2 Factor Authentication
3. Real-time Pro Dash Dashboard – Add dimension to your program with live stats.
4. Customizable Roles for Executives, Compliance Managers, Team Members, Employees, Consultants, and Authorized Representatives
5. Scheduler and Activities Calendar with Task Assignment
6. Incident Reporting on the Product Level
7. Policy and SOP Document Library
8. Licensed Products Tracking
9. Product Type Views
10. Where Products Sold by Country Map
11. Sales Channel Stats and Vendor Management
12. CPSIA Ready Live View for Children’s Products
13. Supplier Stats and Policy Reviews for Each
14. Supplier Audits with Sales Channel Tracking
15. Product Family Feature for uploading one document to many
16. Technical File Product folders format for selling globally
17. Custom Fields on the Product Page to fit your products and capture new ESG requirements.
18. Hide and or Create Custom Folders I
19. Test Lab Stats and Management
20. Test Report Expiration Reminder with Email Alerts
21. Test Plan Section
22. Production Runs / Batch Tracking
23. Shipping Details & Tracking
24. Quality & Inspection Tracking
25. Certificate Management
26. Authorized Representative Access ( for E.U. & U.K.)
27. Ez Uploader makes onboarding a breeze; be up and running quickly.
28. Extensive How to Knowledge Base
29. Great Customer Service
30. Coming Soon…. CO. Comply company branded microsite for employee training!
If you are happy with your current program but need to optimize it and add a 3rd dimension, we have the solution for you.
Complete Compliance with An Eye On Business Transformation™
Comply PRO+ is the most ergonomic, economical, and comprehensive product safety compliance suite for managing your compliance program. It offers an easy-to-use system that can help you document “Due Care” from design to delivery while providing data-driven insights to ensure effective compliance processes. With its intuitive dashboard and automated alerts, you can quickly audit your compliance program and manage all compliance and sales channel activities from one screen. Schedule a Demo today, so we can show you this revolutionary system and get an additional user FREE when you sign up.
Whether you are a manufacturer or Amazon Seller, product safety compliance is essential for any business selling products in today’s competitive markets. A comprehensive product safety compliance program can help protect brands, reduce liabilities, and expand sales channels. Companies must understand their product safety obligations and have the right program to ensure compliance with regulations and retailer requirements.
If you are an Amazon Seller, you may think that by using the manage your compliance dashboard, you would have everything you need to follow Amazon’s policies to manage compliance. Amazon states that you must still follow the laws, regulations, and standards. While their tool will guide you through submitting the necessary proof of compliance for your product category, do you have a program in-house to document these same policies and requirements for other retailers? More importantly, do you have all the other items that constitute a compliance program? Anyone wanting to enter new markets or sell with a major retailer is soon asked to provide proof of compliance with specific policies and evidence of training to ensure you consistently make and deliver safe products. You will find this out quickly if you want to sell at Target or Walmart. This is why it I important for you to build a robust compliance program, no matter how small your company, so that it can scale with you when you grow.
The CPSC not only expects companies to have effective compliance programs in place but to be able to document these processes properly. To build a compliance program that scales with your growth, you should, at a minimum, have the following:
Commitment to Compliance
Recognize that your compliance program is dynamic, involving not only multiple policies, procedures, and manufacturing activities but also the commitment of senior management and the support of all employees, contractors, vendors, and agents to make the program effective.
Assignment of a Compliance Manager or Officer
Appoint someone to handle all compliance-related activities; design an escalation policy to show everyone where to go with issues, concerns, or how to report undue influence by publishing contact details and instructions on how to report.
Written Policies
A policy is essential to any compliance program as it establishes the company’s commitment to providing safe products. It outlines the procedures for ensuring all employees follow established testing, labeling, packaging, and distribution protocols. SOPs are detailed instructions on performing various tasks correctly; they help ensure consistency in product development and provide clear guidance for employees. If you sell children’s Products, you will need a material change and undue influence policy with training. Everyone should have an Incident reporting and escalation policy and a recall plan.
Effective Lines of Communication
Establish a dialogue between management and employees so that when seeking answers to questions or reporting potential violations of law or policies, employees or contractors know whom to turn to for a meaningful response and do so without fear of retribution.
Education and Training
Training is crucial in promoting compliance as it ensures employees understand the importance of adhering to safety standards. It should be mandatory for all staff involved in product design, testing, production, marketing, or distribution.
Auditing and Monitoring
Audit your program at least once a year to evaluate the effectiveness of your program and consider pending changes to regulatory or retailer requirements. Doing so lets you determine if gaps in your current system need addressing.
Documentation and Record-keeping
Documentation should begin during the product design phase and include all third-party certification testing, testing of representative samples, material changes, corrective actions, training materials, and training records. Document the work you have done toward complying with the CPSC’s requirements and adhering to the regulations for your products. In the event of a product recall, this documentation will enable you to show the CPSC in helping understand what may have gone wrong to ensure future product safety and compliance. Retention policies should be set to maintain records for each market where you sell. In the U.S., the manufacturer must keep these records for five years, either in hard copy or electronically, such as a website or Framework like Comply PRO+.
A robust compliance program will protect consumers and businesses by reducing their liability when implemented correctly. Additionally, companies should leverage technology to automate processes and ensure all stakeholders are on the same page. The days of having policies in binders where no one can access them are over, and in the post-Covid world of remote work, they need to be accessible to everyone in your organization.
Comply PRO+ was built for Compliance Managers, Executives, and Business Owners. Schedule a Demo today to see how you can quickly build, manage and audit your compliance program to reduce risk and enter new sales channels and markets.
SaferProducts.gov is where the public can file and read complaints about thousands of consumer products. The CPSC collects reports of harm or potential harm about dangerous or potentially unsafe consumer products. Each report is reviewed by the CPSC staff of investigators and consumer product safety experts to determine what actions should be taken to protect the American public. A report can provide information that may contribute to CPSC’s decision to seek a product recall, seek penalties against any person or firm, or create new safety regulations or take other action authorized by law. Companies should be prepared to respond to reports of harm posted on saferproducts.gov. A best practice is to appoint a leader or the compliance manager to develop internal escalation procedures to gather customer incidents through company customer service representatives so that management can respond to all incident reports and escalate such incidents to determine whether a § 15(b) report is necessary.
After Registering, most businesses can receive notification of reports of harm on saferproducts.gov within the ten business days allotted by the CPSC, either on the website or offline with the CPSC. By acknowledging a report of harm and stating that an investigation is underway, companies can preclude CPSC from taking action until the relevant facts have been thoroughly investigated. As the investigation proceeds and more information becomes available, companies also can supplement their responses. Some of the most effective actions in response to reports of harm posted on saferproducts.gov have included:
· Responding within ten business days, regardless of whether the report has been investigated fully
· Noting an investigation has just begun and will be supplemented promptly as additional information becomes available
· Supplementing responses promptly and regularly as more information becomes known
· Advising consumers to contact customer service and/or provide the company with the product for inspection of the reported harm
· Communicating directly with the CPSC separately and offline instead of on the public website
· Posting nothing online if the consumer has already contacted the company about the incident but advising the CPSC of this fact offline and promptly
· Stressing that all complaints are taken seriously and that the company seeks to investigate them to the fullest extent possible
· Where applicable, stating that the consumer failed to provide contact information or the product for inspection, which prevents the company from responding completely
· Confirming that the product recently was subjected to rigorous third-party, expert, or other testing and analysis and that no problems were found
· Explaining that the product is safe when used correctly (e.g., according to instructions and warnings)
NOTE: Take time to craft any responses on the safer products site and do not be condescending, infer that the consumer is wrong, etc., as consumers look to see how your company responds to safety or quality issues. Best to have the response reviewed internally before posting.
If you still need to do so, please search for your company products on safer products.gov and regularly monitor the site so you can promptly respond to any reports. Search for unsafe products.
Comply PRO+ encourages company registration, and you can sign up right from the SaferProducts.gov section in settings.
Comply PRO+ is a robust consumer product safety compliance management suite built with compliance managers, sellers, and business owners in mind. It is designed to help businesses stay on top of compliance-related activities and create repeatable processes to manage and protect their brands. With its user-friendly interface and advanced features, Comply PRO+ makes it easy for businesses and sellers to manage their compliance activities and for executives and owners to sleep better knowing they can see everything on the PRO Dash dashboard.
Comply PRO+ is the evolution of CPSIA Ready, launched in 2013 and designed to help manufacturers and sellers comply with the implementation of CPSIA but was built primarily for children’s product manufacturers. Leveraging feedback from ten years of user feedback and working with diverse clients selling globally, we made Comply PRO+ to handle the ever-changing global compliance documentation requirements needed to support selling in those markets. With Covid-19 affecting businesses worldwide forever, it became imperative to incorporate all the tools to allow manufacturers and suppliers to manage product development, testing, supplier audits, inspections, and management and storage of certificates into an easy-to-access application.
The interface is user-friendly and intuitive, allowing users to upload essential documents effortlessly and associate one document with many if needed. Furthermore, Comply PRO+ helps businesses identify improvement areas by providing data-driven insights into their operations. If there are empty folders, users can identify risks to eliminate omissions. This feature ensures that companies can maintain their competitive edge while adhering to the requirements necessary for global trade.
One of the key benefits of using COMPLY PRO Plus is its ability to manage suppliers and global retail sales channels. If your business operates in multiple countries, you know how challenging it can be to stay compliant with each country’s different regulations regarding showing proof of compliance. Each major retailer has their specific requirements and protocols to follow. With COMPLY PRO Plus, you can easily manage all compliance-related activities worldwide. This means you can focus on growing your business rather than creating the correct technical file format.
Another benefit of using COMPLY PRO Plus is its ability to streamline your business process to track and document everything from the product development stage to delivery. To comply with the duty to report requirements of the CPSC, you can also record all product safety-related incidents on the product level by recording them in the system.
Comply PRO is a revolutionary software that helps sustainability and regulatory professionals easily manage compliance-related activities specific to certain geographical markets. One of the most significant features of this software is its customizable fields and folders, which allow users to tailor their data according to the unique requirements of the products they sell, and the markets where they sell them.
Comply PRO’s customizable folders enable users to follow the technical file format or add new folders to categorize compliance-related documents and information according to specific criteria. This feature helps track the new sustainability, environmental, social, and governance metrics many retailers are starting to require.
The platform is designed to be user-friendly and intuitive, making it easy for even the most technologically challenged individuals to use. If you still need help, there is a robust support center with detailed instructions on using each system feature. If you still need help, we are a chat message or email away to ensure you get the help you need.
As an Amazon seller, manufacturer, or distributor, you know that managing your business can be a daunting and overwhelming task. If you have been a long-time Amazon seller, you have seen that the days of needing only a test report and a certificate for compliance approval are over. The great news is that Comply PRO+ was also designed with you in mind so you can manage any future requirements.
Comply PRO+ won’t tell you what regulations you need for your products as it is your responsibility to know that or to use an accredited third-party lab to tell you. Failure to comply with product safety regulations can result in hefty fines, lawsuits, recalls, and damage to brand reputation—all things no business wants to deal with.
Comply PRO+ is not only easy to use but also cost-effective. With this platform, you no longer worry about spending a fortune on complex software solutions or developing one in-house. Instead, Comply PRO offers affordable pricing plans without compromising the quality of service provided. Additionally, with its new modules and features in the pipeline, Comply PRO stays ahead of the curve in offering value to its users.
Sign up for Comply PRO+ today or book a demo for us to show you how to streamline your operations, minimize risk, and protect your brand. With Comply PRO+, you can expect exceptional support and experience peace of mind so that you can focus on what matters most – growing your business.
Complete Compliance with An Eye On Business Transformation™
