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2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013
 

2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

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Frequently asked questions about importing consumer products.

Frequently asked questions about importing consumer products.

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  • What is the length of an average detention? What factors affect the length of a detention (unanalyzed)? 99.93% of cargo that were of products in codes that are of potential interest to CPSC based upon potential hazard of product class.
  • What is the length of an average detention? What factors affect the length of a detention (unanalyzed)? 99.93% of cargo that were of products in codes that are of potential interest to CPSC based upon potential hazard of product class.
  • What kind of products are being stopped?3,694 samples that directly mapped to the 1,400 shipments
  • What mode of transport are products are being stopped?3,104 mapped to 1,150 entries – data cleaning necessary to study missing data.
  • How often are violations found?
  • What types of problems are being seen in products at import?
  • What are some examples of the products that have been removed from commerce due to the work on the Risk Assessment Methodology?
  • Any linkage to Intellectual Property Rights?Since CPSC has implemented its own Risk assessment strategy we are finding more and more connections to IPR and Health and Safety? While it does not appear to be an direct correlation it is true that importers who tend to avoid health and safety regulatory requirements, they too will avoid other agency requirements as well, including mis-classification, and port shopping.CPSC has been working closely over the past two months with the IPR center in Virginia to align our enforcement efforts.
  • What are the potential benefits, measured or anticipated, of having a fully built Production System?Expect to grow with additional efficiencies and staff.
  • What is the benefit to society?–Creation of a production risk system may save an estimated 19 lives and prevent an estimated 20,600 to 23,000 injuries annually that occur as a direct result of hazardous imported consumer products.– By identifying lower-risk importers and manufacturers who supply consistently compliant products into U.S. commerce, the CPSC can allow them reduced review at importation, resulting in reduced port processing and savings of costs and time. Through improved targeting, high-risk cargo will be stopped at ports of entry. Thus, the system will protect companies and industries better from the cost and legal exposure of distributing and retailing products that are hazardous and may ultimately be subject to recall.
  • YES, but if an importer is responsive and complying with addressing the problem, Compliance uses it’s discretion and would say that a separate report is not necessary.When CPSC screens a product at importation and finds the product to violative, we request the certificate to see if the product was tested. CPSC if first and foremost concerned about the health and safety aspect of the product. We currently treat certificates as a secondary violation. If however, product continues to be entered and product continues to not pass, it is highly unlikely that CPSC will allow the cargo to move until product is tested. This causes great delay in delivery schedules and costs for storage.

2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013 Presentation Transcript

  • Frequently Asked Questions About Consumer Product Imports Panel 5 Carol Cave John Blachère Seattle Safety Academy 2013 Analysis dates cover 10/1/2011 to 9/4/2013, unless otherwise noted.
  • How Does CPSC Review Shipments at the Ports? Seattle Safety Academy 2013 Prior to Port At Port Commerce No Exam
  • Seattle Safety Academy 2013 Prior to Port At Port Commerce No Exam How Does CPSC Review Shipments at the Ports?
  • Seattle Safety Academy 2013 Prior to Port At Port Commerce No Exam How Does CPSC Review Shipments at the Ports?
  • Seattle Safety Academy 2013 Prior to Port At Port Commerce No Exam How Does CPSC Review Shipments at the Ports?
  • What is the Length of a Detention? How Often Does CPSC Detain Shipments? Seattle Safety Academy 2013 Shipments Estimated number of shipments eligible for examination* 2,000,000 Detentions 1,400 Detention Rate 0.070% Average Detention Time 13.4 days * - Entry data collection based upon pilot system product codes
  • What is the Length of a Detention? How Often Does CPSC Detain Shipments? Seattle Safety Academy 2013 • Detention time can be reduced by importers by responding promptly to CPSC and CBP when requests for information are made. • 99.93% of eligible shipments to the CPSC were not detained.
  • What Products are Being Detained? Seattle Safety Academy 2013 55% 14% 9% 3% 5% 14% Samples Toys Fireworks Clothing Holiday Light Sets Other Electrical Products All Others
  • How Did Shipments that CPSC Detained Enter the United States? Seattle Safety Academy 2013 6% 2% 6% 86% Samples Air Rail Truck Sea
  • How Often are Detained Shipments Found to be in Violation of a Regulation? Seattle Safety Academy 2013 Shipments Rate Violations Found 1,022 77% Violations that Required Seizure 622 61%* Correctable Shipments 400 39%* • At least one violation found. Multiple are possible. • 1,400 shipments detained October 1, 2011 to September 5, 2013. *- of violative shipments (1,022)
  • What Types of Violations are Seen at Import? Seattle Safety Academy 2013 Primary Shipments* Rate** Lead 472 34% Mechanical 206 15% Phthalates 113 8% Fireworks 92 7% Electrical 87 6% Chemical 36 3% Lighters 22 2% Flammability 19 1% Secondary Tracking Labels 534 38% Certificates 492 35% *- Shipments can have more than one violation type. **- 1,400 shipments detained October 1, 2011 to September 5, 2013.
  • What are Some of the Larger Seizures? • 1.5 million fireworks were seized at the port of Baltimore for overloaded pyrotechnics in June 2012. • 260,000 lighters were seized at the port of Newark in March 2011 . • 100,000 lighters were seized at the port of LA-Long Beach in August 2011 . • More recently, in July 2013, CBP seized 70,000 units of counterfeit consumer products valued at $3.9M at the port of Newark based upon targeting managed by CPSC. Seattle Safety Academy 2013
  • Is There a Linkage Between Health and Safety and Intellectual Property Rights (IPR) Violations? • RAM Pilot Trends • Intellectual Property Center (Virginia) Seattle Safety Academy 2013
  • What is the General Concept Behind CPSC’s Pilot System for Risk Assessment? Integrates available risk information to model and support Commission enforcement strategy involving product hazards at importation. Potential sources of risk data include: –shipment (CBP) –case history (CPSC & CBP) –screening history (CPSC) –injury and death (CPSC) –commercial information (Third Party) Seattle Safety Academy 2013
  • What Improvements are Expected from CPSC’s Production System for Risk Assessment? Seattle Safety Academy 2013 • Higher rate of product hazard detection at import. • Higher volume of shipments sampled and detained annually at import. • Fewer shipments unnecessarily stopped • Reduced recalls of dangerous products in commerce. – In FY 2012, 3.6 million non-firework products were stopped from entering commerce. The number of shipments examined grew 190% over FY 2007 levels while increasing the violation rate by 25% over the same period.
  • What are the Societal Benefits to CPSC’s Production System for Risk Assessment? • Save Lives and Prevent Injuries • Facilitate Legitimate Trade • Minimize Costs for the Trade, Government Agencies and U.S. Customs • Proactively Monitor Compliance Seattle Safety Academy 2013
  • Other Questions • If I am an importer who brings in product that does not meet mandatory requirements, am I required to file a report with the Commission? • What is the agency policy with respect to enforcement of certificates at ports of entry? Seattle Safety Academy 2013