The Consumer Product Safety Commission has announced proposed rules regarding the requirements for a “reasonable testing program” and other certification testing and the requirements for component part testing pursuant to the Consumer Product Safety Improvement Act. Domestic manufacturers and importers of children’s products and other products subject to a CPSC regulation or ban should track the development of the proposed rules and may consider incorporating some of the provisions now, in anticipation of a final rule.
Please view the Kelley Drye client advisory for more details regarding the “15 Month Rule” and component parts testing.