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CPSC Commissioner Complains About Registration Rules for Small Batch Mnfr Relief

Consumer Product Safety Commissioner Anne Northup, in her Safety and Common Sense blog, complained that the registration requirement that allows small batch manufacturers to forgo third-party tests for compliance with certain children’s product safety rules until alternative tests or an exemption are issued, is too revealing as to their revenue and production data, and that it is unrealistic to expect these manufacturers to possess the legal knowledge necessary to provide the evidence and arguments for maintaining confidentiality.

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(Generally, all children's products must be third party tested and certified as compliant with all applicable children's product safety rules. However, Public Law 112-28, recently amended CPSC's requirements by allowing it to establish alternative testing requirements for certain products for small batch manufacturers, or if alternatives are unavailable or economically impracticable, an exemption from certain of the third party testing requirements. Registration for this benefit is required. See ITT’s Online Archives 11122709 for summary of CPSC notice on this relief and the website registry, and 11080230 for summary of P.L. 112-28.)