Comment from Douglas Boysen

Re CPSC Docket No. CPSC-2013-0017: Please revise the proposed rule for 16 CFR Part 1110.11(a)(7) to remove the requirement to provide the street address where products are manufactured. This new requirement is incremental to the current requirement in the “Final Rule” for 16 CFR Part 1110.11(e) (as published in the Federal Register, 11/18/08), and will potentially be quite detrimental to the livelihood of small companies like ours. Our company operates in a very small and highly competitive niche on the perimeter of the toy industry, yet our products are subject to all regulations promulgated by the CPSC. One of our distinctive competencies is sourcing innovative, safe, high-quality products from China. Our company must be very cautious about protecting the identities of our suppliers from competitors and even from large customers for fear of them going directly to the manufacturer and circumventing our company. The identities of our suppliers are a trade secret. The proposed rule will allow anyone to obtain a Certificate for our products and, with modern technology, to easily identify the manufacturer using the street address information. The current “Final Rule” requires revealing the street address only “If the same manufacturer operates more than one location in the same city.” As required, we have designed our certificates to contain the city, country and administrative region where the product was manufactured. This location information, without the street address, has been perfectly satisfactory to date; revealing the street address will add no value to the purpose of the certificate. (Of course, the identity of our suppliers may be obtained upon request by any regulatory agency.) Respectfully, we request that content requirements for Certificates of Compliance remain as is for the place of manufacture (16 CFR Part 1110.11) and not be revised to include the manufacturer’s street address. Thank you.