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Discussion of what CPSC looks for when selecting containers for audit and the process of entry.

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  1. 1. U.S. Consumer Product Safety Commission From Port to PortThis presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
  2. 2. Coordination with Customs• Border Interagency Executive Council (BIEC)• ITDS/ Risk Assessment Methodology• Joint audits of importers (informed compliance)• Importer Self Assessment (ISA) Product Safety 2
  3. 3. What Triggers and Inspection?• Repetitive use of foreign supplier found in violation• Incorrect filing of Manufacturer ID on entry• Class of product under review by CPSC to monitor compliance• Overlapping IPR and Safety concerns• Monitoring firm under consent order
  4. 4. Routine Enforcement• Yearly Programs Coordinated with CBP for routine enforcement of Mandatory standards – Rule sets developed in partnership with CBP• Local Operations formulated based on port specific activity• Targeted Exams• ICE Partnership 4
  5. 5. How are potential violations investigated?• Common Sense Approach – Counterfeit versus Safety Defect• Pre-screening of products containing lead for rapid decision making of shipment• Importer Inspections (sometimes jointly with CBP)• Domestic visits to retailers, wholesalers and consumers 5
  6. 6. Common Patterns Seen by CPSC• Un-manifested and un-invoiced merchandise• Missing invoices• Delay of entry documents from broker• Certificate identifies a non-accredited lab• Foreign Manufacturers substituting components from unapproved suppliers• Variations in Enforcement by Port
  7. 7. Certification at the Ports• There is currently no requirement to file a certificate with CBP or any government agency as part of the entry process or otherwise• CPSC may, by rule, provide for electronic filing of certificates up to 24 hours before arrival• Electronic filing is currently being evaluated with Customs for submission at entry (1110 Rule) 7
  8. 8. ITDS/ACE• Systems and Process integration with CBP• Development of Risk Scores• In the Fall of 2011, CPSC became the only agency to receive a live data feed from CBP• This web services tool gives qualified CPSC staff access to much better information for targeting “high risk” consumer products 8
  9. 9. CPSC’s RAM Strategy• Expedites the Import Process• Identifies multi agency violations (IPR/Health and Safety)• Facilitates the flow of legitimate trade
  10. 10. Informed Compliance• Joint Programs by class of product• Joint Inspections – Provides specific guidance on CPSC regulations – Provides specific importation requirements for future activity with Customs• Informed Compliance Inspections (ICI) 10
  11. 11. Importer Self Assessment- Product Safety• Allows companies to apply for a program that labels them “low-risk”• Provides benefits – Expedited testing – Conditional release of goods• Good Importer Practices• Where do I get more Information? – 11
  12. 12. Quarterly Import Stoppage Report 13
  13. 13. Quarterly Import Stoppage Report 14
  14. 14. Avoiding the Pitfalls that could Delay Entry• Make certificates readily available• Ensure goods are classified appropriately• Include product detail on invoice• If importing ATV’s have a CPSC approved action plan on file• Make sure 3rd party testing body is accredited by CPSC• Sign up for ISA and ISA-PS 15
  15. 15. Pitfalls Continued• Ensure the correct citation to each CPSC product safety regulation or statutory requirement to which the product is being certified on the certificate.• Don’t import childrens upper and outerwear with drawstrings.• Know your suppliers 16
  16. 16. QuestionsCarol Cave, Assistant Executive Director, Office of Import Surveillance 17