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Product Safety Mark Requirement Eased for Household Refrigerators

Monday, August 05, 2019
Sandler, Travis & Rosenberg Trade Report

The Consumer Product Safety Commission has issued a policy statement indicating that effective Aug. 2 it will not pursue compliance or enforcement actions against importers, manufacturers, or private labelers of household refrigerators for failure to issue, provide, or make available to the CPSC the general conformity certificate required by the Consumer Product Safety Improvement Act, provided that the product bears an appropriate safety certification mark indicating compliance with UL Standard 60335-2-24.

Under the CPSIA, GCCs must certify that, based on a test of each product or upon a reasonable testing program, the covered product complies with all applicable rules, bans, standards, or regulations. However, the CPSC states that in this case a certification mark indicating compliance with the UL standard is an appropriate proxy for a GCC indicating compliance with the Refrigerator Safety Act and its implementing regulation, 16 CFR Part 1750.


The CPSC states that if a household refrigerator does not bear this mark none of this policy, the enforcement discretion described therein, or the implications of such discretion will apply. The CPSC warns that any misrepresentation or omissions regarding a household refrigerator bearing such a mark could subject the firm to compliance or enforcement action and potential civil and/or criminal penalties.

For more information on product safety issues, please contact trade attorney Beth Ring at (212) 549-0133 or trade consultant Ned Steiner at (202) 730-4970.

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