CPSC General Counsel Clarifies Distributor Responsibilities for Children's Apparel

Ever since the early years of our industry there aren't many promotional products distributors who would describe themselves as manufacturers. But under the Consumer Product Safety Improvement Act (CPSIA), the majority of promotional products distributors—at least those who buy blank apparel from a wholesaler and then send it out to have it decorated—are just that, manufacturers in the eyes of the law. Now for the first time, as a follow-up to questions posed at PPAI's Product Safety Summit this past August in New Orleans, the General Counsel of the U.S. Consumer Products Safety Commission (CPSC) has put in writing exactly how the senior staff at the Commission regards the responsibilities of distributors who decorate. This written guidance doesn't change anything from the Commission's perspective but it might surprise many distributors to learn of the extent of their responsibilities under the law.