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CPSC Seeks to Renew Information Collection on Third-Party Testing of Children’s Products

Friday, January 29, 2016
Sandler, Travis & Rosenberg Trade Report

The Consumer Product Safety Commission has submitted to the Office of Management and Budget a request to extend, without change, the approval of an information collection for third-party testing of children’s products. This request would also consolidate within this information collection the estimated burden for meeting the marking and labeling requirements in 14 rules on durable infant and toddler products. Comments may be submitted no later than Feb. 29.

Records required by the CPSC rules on testing and labeling pertaining to product certification and on representative samples for periodic testing of children’s products include a certificate and records documenting third-party testing and related sampling plans. These requirements largely overlap the recordkeeping requirements in the CPSC rule on conditions and requirements for relying on component part testing or certification. The component part rule also requires records that enable tracing a product or component back to the entity that had a product tested for compliance and requires attestations of due care to ensure test result integrity.

In addition, each of the CPSC’s 14 rules for durable infant and toddler products contains requirements for marking, labeling and instructional literature. These include a permanent label or marking that identifies the name and address of the manufacturer, distributor or seller; a permanent code mark identifying the date of manufacture or other product identification; and easy-to-read and –understand instructions regarding assembly, maintenance, cleaning, use and adjustments.

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