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Administrative Law

: Customs Law

CPSC Activity and Big Bugs

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Here are some things I need to get off my desk before they are too old to be of use to you.

On June 29, the CPSC published a Federal Register Notice proposing a rule to implement the requirements for consumer registration of durable infant or toddler products. Typically, I do not think of CPSC issues as "customs law," but Customs and Border Protection will be involved in enforcement relating to imports, so we all need to have our eyes open for these issues.

Some of the requirements include:

Postage paid consumer registration cards in each product and internet registration option
Manufacturer database of registered consumers and their products
Manufacturer name and contact info permanently on the product in English, legibly, and conspicuous (sound familiar?)
Tracking labels to show manufacturer or private labeler, location and date of production, manufacturing lot

Comments are due September 14, 2009

Also on the CPSC front, the Commission voted for a two-year stay of enforcement of the lead content standards for bicycles and bike parts. I've been following this closely because I have an interest in the industry. From what I can tell, the problem is that there is lead in bikes. The highest concentration appears to be in valve stems. I'm pretty dubious that normal use, even by kids, will result in lead contamination. I have never seen a kid lick the handlebars or try and inflate the tires by mouth. I guess it could happen. The problem for the CPSC is that the statute mandates that the requirement apply. It will be interesting to see whether the industry adopts manufacturing changes or gets Congress to change the law. I'm sure they are talking to the all-terrain vehicle people.

Also, Customs seized gigantic beetles. You know I can't resist a Customs and Border Protection animal story.

Full post as published by Customs Law on July 01, 2009 (boomark / email).