Trade Groups Urge CPSC Engagement With Industry on New Entry Requirements
The Consumer Product Safety Commission should hold a dialogue with the trade community before it finalizes new entry documentation requirements, said a group of trade associations a letter to the commission dated March 14. CPSC proposed in May 2013 to require product safety compliance certificates to be filed with CBP at time of entry (see 13051018). That is a “significant change to current supply chain operations and will have a major adverse impact on businesses’ operations,” said the letter. The changes merit that CPSC hold a public form “as soon as possible,” said the trade groups. “It is important for the CPSC to fully understand how the current entry process works and how this change would not only impact the industry, but Customs and Border Protection (CBP) and the CPSC as well,” it said.
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The letter was signed by a variety of trade groups including the American Association of Exporters and Importers, the American Apparel & Footwear Association, the United States Fashion Industry Association, the National Customs Brokers & Forwarders Association of America, and the U.S. Chamber of Commerce. Many of these associations had weighed in against the new requirements in comments submitted to CPSC following publication of the proposed rule. “The surge of entry documents, almost entirely on products that are compliant with product safety rules, will add increasing costs to both companies and to the agencies,” said the AAFA in July (see 13073014). Increased processing times could cause backlogs that “could magnify across ports, especially during peak seasons, as the impact of federal budget cuts and sequesters limit personnel and require enforcement resources to be allocated to meet risk,” it said.
In their March 14 letter, the trade groups continued to express opposition to the proposed new entry documentation requirements, but conceded that CPSC’s desire for more data to improve its risk assessment and targeting efforts is valid. Given the heavy new burden the new requirements would place on industry and government alike, however, engagement with stakeholders is critical. The trade groups said CPSC should hold a public workshop soon to discuss current procedures, the impact of the proposed new requirements, and how to incorporate the new documentation into the Automated Commercial Environment (ACE). The letter also said CPSC should work with industry to create a clear list of products for which product safety certificates are required. The workshop should include representatives from CPSC, industry, logistics providers, and CBP, the trade groups said.
In the long term, CPSC should establish a permanent stakeholder advisory group that would serve to “regularize needed input into product safety issues of mutual importance,” said the trade groups. The letter cited CBP's stakeholder advisory group as an example of what such a group would look like.