“Safety is smart business.”
That succinct statement kicked off the annual training symposium of the International Consumer Product Health and Safety Organization – better known as ICPHSO – this week in Orlando, Florida. Kevin Nolan, president and CEO of GE, delivered the opening keynote, telling attendees that safe products help a brand build consumer confidence and a solid reputation.
Nearly 800 product safety professionals and regulators from around the globe attended the annual gathering to exchange ideas, review regulatory updates and more. Several PPAI member companies attended, including 4imprint, Bamko, QIMA and SnugzUSA.
“Communication, coordination and compliance are always emphasized,” said Sanjay Kotia, CPSC, MAS, manager of product compliance & quality assurance for SnugZ USA, PPAI 100’s No. 6 supplier. “There are always updates to share, and PFAS, EPR and eFiling are especially hot topics.”
Many panels discussed how to manage compliance with various laws regulating the same chemical or issue across jurisdictions. Sessions throughout the conference highlighted the importance of thorough documentation, as well as communication and collaboration across both internal teams and the entire value chain. A few takeaways:
- Reaching out to consumers is a key element of a successful product recall – and this is especially challenging for promotional products, as the buyer often doesn’t have a record of who received an item.
- Just because a product meets a standard doesn’t mean it can’t be subject to a recall. It’s important to focus on risk assessment and reduction in addition to regulatory requirements to promote safer products design from the start.
- U.S. states are ramping up chemical regulation in response to public perception that the federal government isn’t acting. This has created a patchwork of different rules that pose a significant compliance challenge.
- The U.S. Environmental Protection Agency has adjusted the reporting requirements for PFAS under the Toxic Substances Control Act. This includes some welcome changes, including exemptions and a de minimis threshold, but it remains unclear exactly what must be reported.
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- PFAS and other chemical restrictions pose a major challenge, with different definitions across different jurisdictions. Panelists recommended careful documentation as a foundation for compliance, as well as keeping track of emerging laws and changes to existing regulations.
- The push for minimum recycled content may conflict with chemical restrictions. Older products that met standards at the time may no longer be compliant, creating potential for contamination with prohibited materials like PFAS or heavy metals.
- The European Union has updated its General Product Safety Regulation, which applies to most consumer non-food products. The updates include clearer expectations and responsibilities, as well as stronger requirements for traceability and transparency. Panelists said this transitions GPSR from a checklist to an opportunity for more strategic engagement with stakeholders across your organization.
- The EU is working on a product safety and circularity study with over 10,000 respondents from 10 member countries. The report should be published later this year.
- Greenwashing continues to pose a regulatory risk, as more countries seek to regulate claims. Avoid generic phrases like “eco-friendly” or “sustainably made” and only make statements that you have data available to verify. Even subtle, nonverbal elements like using the color green or adding leafy imagery to your website can be considered a “claim.”
- In a panel on state extended producer responsibility laws for packaging across the U.S., panelists urged attendees to collect key data, such as material type, weight by component (not SKU) and recyclability, as well as documentation from suppliers. They warned that the financial impact is significant but pointed out that despite different rules in different states, a single entity – Circular Action Alliance – is managing compliance programs for all active states so far.
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The U.S. Consumer Product Safety Commission, previously a staple of the conference, was notably absent. Almost a year ago, President Donald Trump removed all three Democratic CPSC commissioners, and a leaked draft budget suggested eliminating the agency and rolling its functions into the Department of Health and Human Services.
