At long last, CNN is doing some reporting on one of the most important stories of the year--the CPSIA. In particular they reported on the damage the permanent labeling issue is wreaking on businesses as they try to deal with vague rules, that add huge expense and administrative costs, and come with clear penalties for non-compliance. I have responded to CNN with this comment:
Thank you for covering this very important story. At a time when the government is spending hundreds of billions of dollars to save/create jobs and stimulate our economy, it doesn't make sense that it is imposing needless (and vague) but very strict and expensive requirements on businesses.
The purpose of this rule is assist consumers in returning products in the case of a recall. However, it is so broad it includes products that not only have never had a recall, they are unlikely to ever have a recall. Case in point, at the recent CPSC hearing they has a serious discussion about the practicability of permanently marking SOCKS! Now when was the last time there was a sock recall?
Additionally, of the proportionately few products that are recalled, the problem in getting the products back is not in the consumer identifying if their product is subject to the recall or not, it is in getting the word to them in the first place AND the consumer consenting to return the product.
Not only that, but many products have such a short life cycle (ie. bubble gum toys that are also subject to the law) that the toys are long ago disposed of before a recall would ever come about.
In our case, we sell small batches. The cost is prohibitive and will force us to eliminate many of our natural products from Europe. In the unlikely event of a recall, in most cases we could recall ALL of a given item for less than the cost of the permanent labeling.
However the law does not inherntly allow for such flexibility (voluntary permanent labeling based on individual circumstances), and the CPSC does not seem willing to grant such flexibility, despite the repeated claims by Congress that the CPSC has all the flexibility in the world to make this law work properly.
While Congress and the CPSC dithers, American businesses are shrinking, closing, and moving production to China, the only place where you can produce in high enough quantities to make the economics of this law work.