Distributor to Supplier: Is this Product OK for Children?
I received a call last week from a distributor concerned about an order she had recently shipped through an industry supplier for a children's event. The distributor told me she had inquired of the supplier's customer service rep if the product was OK for children but was now wondering what else she should have done. Here is a capsule of what I recommended.
Start by asking for the product's General Certification of Conformity (GCC) as well as its most recent test reports. A GCC is required by federal law for every consumer product subject to any rule or regulation enforced by CPSC. Regardless of what the test report says, the GCC is the best way to find out if the supplier considers the product as a "children's product." If the supplier does not, even if the test report passes CPSIA standards, it is a red flag that the supplier might not be monitoring each production run to children's product standards.
Recommendation 1 (Children's Product): If you sell a product that you know is intended for children, be sure that the supplier acknowledges through the GCC that it is a children's product. Then, if something goes wrong later, you won't risk being in the position of the supplier saying "we didn't know it was for children and we never said it was a children's product."
So how do you find out from the GCC if the supplier considers the product a "children's product?" You do so by examining the section of the GCC listing the applicable regulations. CPSIA requires the importer or domestic manufacturer to list every CPSC-enforced rule that applies to the product. If the supplier doesn't have a GCC for the product, or if the section noting the applicable rules is blank, it means that the supplier is not acknowledging that the product is a children's product or a children's toy.