I own a small business making fabric baby carriers. My sales, in terms of number
of carriers sold, are in the hundreds each year, not the millions or even the
thousands. Because of this, and because of my record-keeping, I can currently
already pull up the name and address of anyone who's ever bought a carrier from
me, and I can sort that by type of carrier and date of sale. Soon, with CPSIA
rules that go into effect in August, I'll also be able to sort by date of
manufacture.
A requirement to include a postage-paid postcard with every carrier would be
overly onerous and costly to my business. I can absolutely see the need for this
with major manufacturers, who largely do not have any interaction with their end
user. On the other hand, small businesses like mine sell almost exclusively
directly to the end user. In fact, I currently have more thorough information
for my customers than I could ever hope to receive via registration cards, which
do not have a 100% return rate. Each person who buys a Wallypop carrier MUST
give me their name and address, at a minimum. Most smaller baby products
manufacturers who sell direct to the customer work in a similar fashion.
Please consider, when making the final ruling on this aspect of the CPSIA,
making exceptions for businesses that can already provide this information on
demand. Perhaps requiring a postage paid registration card only if the
manufacturer does not already have this information available to them.
This will fulfill the intent of the law, which is to ensure that manufacturers
have the ability to contact their customers in the event that such contact is
needed.
Comment from Sarah Reid
This is comment on Proposed Rule
Requirements for Consumer Registration of Durable Infant or Toddler Products
View Comment
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