ICPHSO CPSC PORT to PORT
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Discussion of what CPSC looks for when selecting containers for audit and the process of entry.
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ICPHSO CPSC PORT to PORT
- 1. U.S. Consumer Product Safety Commission From Port to Port This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
- 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. 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. 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. 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. 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. 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. 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. CPSC’s RAM Strategy • Expedites the Import Process • Identifies multi agency violations (IPR/Health and Safety) • Facilitates the flow of legitimate trade
- 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. 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? – www.cbp.gov 11
- 13. Quarterly Import Stoppage Report 13
- 14. Quarterly Import Stoppage Report 14
- 15. 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
- 16. 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 children's upper and outerwear with drawstrings. • Know your suppliers 16
- 17. Questions Carol Cave, Assistant Executive Director, Office of Import Surveillance ccave@cpsc.gov 17
Editor's Notes
- I was asked to cover some of the actvities that CPSC and CBP are working on. There are many critical areas in which we work closely with U.S. Customs and Border Protection. Here are some of them. The first is the Border Interagency Executive Council. This group formally called the Import Safety Working group was formed in support of the White House initiative to implement the National Strategy for Global Supply Chain Security.International Trade Data System/ CPSC’s Risk Assessment Methodology is a result of Section 222 of the CPSIA.Several times per year, we partner with CBP’s regulatory audit division to identify importers for joint audit/ inspection. Importers that meet both agencies requirements are identified and a joint team goes into conduct a focused assessment while simultaneously conducting a full field investigation. This joint activity provides specific guidance on CPSC regulations and provide specific importation requirements for future activity with Customs. The holistic approach addresses all CBP and CPSC issues related to product safety at one time.The Importer Self Assessment Program is a “Trusted Trader Program Developed to align with U.S. Customs Trusted partner programs.
- There are many overlapping characteristics with importers who allow the importation of products with counterfeit as well as those that have no understanding of U.S. safety laws.
- The Safe Port act requires federal agencies to align with “Single Window Environment” by using ACE as the single collection system for import data and documentation. To compliment the process the CPSIA required CPSC to develop a risk assessment methodology for addressing hazardous products at importation. Of course this was an unfunded mandate, still unfunded BTW, but never the less CPSC stood up a pilot system to 1) assess for Congress what resources were necessary to support a full production system and 2) to isolate with our limited resources ,products that have the greatest degree of risk for inspection at U.S. ports of entry.CPSC currently receives real time entry data that is risk scored for health and safety requirements and is reported to CPSC staff around the country for purposes of inspection.
- Through out staff located at the Commercial Targeting and Analysis Center (CTAC) in Washington DC, we currently undertake about a dozen joint nation-wide operations each year lasting 2-3 months in length. Recently concluded operations included mattresses, children’s imitation jewelry and geographic toy operation where zip codes are used to identify ultimate consignees that repeatedly import hazardous toys.Joint inspection I discussed on an earlier slide.Informed Compliance Inspections (ICI) is a relatively new program. It is an announced onsite importer visit for the purpose of providing CPSC regulatory information, resources and guidance to a firm to increase compliance with CPSC requirements. The goal of the ICI is to eliminate or reduce the necessity for future CPSC enforcement action. The ICI is not intended to be enforcement oriented and does not replace the Limited and Full Establishment inspections.The ICI is to be used with firms with only limited CPSC import exam history, no recent (within the last 5 years) CPSC establishment inspections and that have limited CPSC Compliance actionable violations.The intent of the ICI is to address the root cause of non-compliance as early as possible, by providing targeted CPSC regulatory compliance information and resources directly to the firm. Basically the goal is to enable those importers who wish to be compliant to have the tools that they need to be compliant.
- The Importer Self Assessment- Product Safety Program was created several years ago in partnership with CBP and prior to the National Security Council strategy to align trusted trader programs.To apply for the CPSC part of the program one must first be cleared through the US Customs CTPAT Program (cargo security) then the CBP ISA (Importer Self Assessment) Program (financial piece) and then you can apply for this program.The programs provide for a multitude of benefits including expedited testing, mitigating factor in a civil penalty and conditional release of goods when product is stopped for exam. Most importantly it allows companies to apply for a program that labels them as “low risk”This program was recognized by the World Customs Organization (WCO) for its innovative approach in aligning trusted partnership programs.The application can be found on the U.S. Customs website by simply searching on ISA-PS. The evaluation process takes approximately 4-6 months after an application is received and evaluates internal controls of a company.
- This is a chart that shows where CPSC found violations during fiscal year 2012. The other children’s products section is where a product was collected ,but was found to have only a secondary violation such missing a label , certificate .…………………………. And the other violations codes are for strangulation/suffocation type hazards.It is important to note that this chart only reflects cases where a final disposition was made and entered into our system of records.
- Beginning with the first quarter of 2012, we began publishing details of seizures of regulated products. This information has been issued as a press release and comes out every quarter. The third quarter report was release last week.It can be found on our website, under press releases.In the near future, we will be posting such information in real-time as the seizures happen, so you will see this document disappear and be replaced by a searchable database.
- This is what a page of a published report looks like. It lists the foreign manufacturer, the importer, the product name, the country of origin, the violation, and the lot size.Importers need to be aware of this report for two reasons. First, you probably don’t want your company to appear on the report.Second, you can use this as a resource. If you are doing business with or planning to do business with one of the foreign manufacturers that produced a violative product, you might want to ask a few more questions and put a few more controls in place to make sure that they will be delivering a compliant product.
- Thank you for letting me share the CPSC Import Safety Program with you. I am happy to answer any questions.