CPSC's Reasonable Testing Program

CPSC's recent webinar slides provide brief preview of minimum compliance standards for non-children products that importer is required to comply with. Those importers that would like to keep their expenses to the minimum, thereby forgoing third party testing fees, must base their certification on a "reasonable testing program," which should contain:

• product specifications
• applicable certification tests
• production testing
• remedial action plan
• program design and implementation documentation

The above guidelines, without more, seem to be very lax, so long as you know what is meant by "applicable." In other words, one should know what to test for, and that requires knowledge of CPSIA and other CPSC regulations. To make the compliance easier, lawcustoms designed questionnaire. The questionnaire, however, is a work in progress and is currently in the process of being updated.