Nearly two dozen trade associations representing importers, manufacturers, retailers and others recently requested that House appropriators consider several priorities in determining the agency’s fiscal year 2017 budget, including import surveillance and trusted trader programs.

The associations expressed support for the CPSC’s presence at U.S. ports of entry and the ongoing development of its risk assessment methodology that will be used to analyze import data to identify high-risk imports. At the same time, industry believes that additional coordination and consultation with all affected trade stakeholders is needed for further development and implementation of the RAM system to ensure that legitimate commerce and entries of compliant products are not stopped or unnecessarily delayed during the CPSC’s import screening process. The associations said they have seen significant and unnecessary delays for compliant goods as the CPSC has piloted its import surveillance programs but that importers are not informed about why their shipments are targeted and are frustrated by the CPSC’s lack of communication on this issue.

The letter also raised concern about the CPSC’s continued requests for authorization for user fee authority to pay for the import surveillance program. Import surveillance and the RAM program are core CPSC enforcement functions, the letter said, and as such should be funded through the normal congressional appropriations and oversight process. In addition, the CPSC has not yet engaged the trade community on exactly how the proposed fee would be collected or used.

Further, the associations strongly encouraged the CPSC to work with stakeholders to develop “a vibrant trusted trader program that provides actual, significant trade benefits for those low-risk importers willing to subject their product safety and import process and supply chains to CPSC scrutiny,” such as fewer examinations and data requests.


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