Consumer Product Regulations
The Consumer Product Safety Commission (CPSC) oversees all consumer product regulations that are not regulated by the Federal Drug Association (FDA) (drugs, cosmetics, supplements, food, medical devices), the United States Department of Agriculture (USDA) (meat, eggs, catfish, organics), and the Environmental Protection Agency (EPA) (pesticides, insect repellants).
What does this leave?
The CPSC regulates children’s products, cleaning materials, art supplies, jewelry, luggage, fireworks, and recreational products – to name just a few. Rather than being commodity-focused, the CPSC tends to be completely safety focused.
Hazardous substances, choking hazards, safety labeling and product recalls are their major concerns. They can take severe monetary enforcement, with civil judgments in the millions of dollars.
It is important to have an advocate to help guide you through the CPSC system and get your consumer product labeling in compliance.
Hazardous Substance Labeling
Consumer commodities are distinguishable from the general category of consumer products in that they are consumer products that are consumed by their use. Products in this category are subject to additional labeling requirements coming from the Federal Trade Commission’s (FTC) regulations.
Hazardous substances are typically cleaning materials or other household chemicals that can be combustible, skin irritants, corrosive, or otherwise toxic. These products, whether they are consumer commodities or not, require very particular safety labeling to ensure consumer safety.
Terms to Familiarize Yourself With
Hazardous Substances – Substances or mixtures of substances that are toxic, corrosive, irritants, strong sensitizers, flammable or combustible. They can also generate pressure through decomposition, heat, or other means, or cause substantial personal injury or illness as a result of handling or use, including reasonably foreseeable ingestion by children.
Consumer Product –A product for personal or household use.
Consumer Commodities –A product for consumption for purposes of personal care or in the performance of services ordinarily rendered within the household, and which is consumed or expended in the course of use.
Certificates of Conformity – A certificate issued by a manufacturer or importer, certifying to the compliance of a consumer commodity with an applicable CPSC standard.
How an FDA Attorney Can Help
An experienced attorney can help you by guiding you through the process, classifying your products, reviewing your labels, and representing you to the CPSC in both imports and domestic enforcement actions.
Solve Your FDA Problems
Take the first step to freedom and schedule a call with us today.