2013 consumer product imports - frequently asked questions, safety academy 2013

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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.

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Frequently asked questions about importing consumer products.

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Page 1: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

Frequently Asked Questions About Consumer Product Imports

Panel 5Carol Cave

John Blachère

Seattle Safety Academy 2013

Analysis dates cover 10/1/2011 to 9/4/2013, unless otherwise noted.

Page 2: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

How Does CPSC Review Shipments at the Ports?

Seattle Safety Academy 2013

File Entry

Prior to Port At Port

Commerce

No Exam

Exam

Page 3: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

Seattle Safety Academy 2013

File Entry

Prior to Port At Port

Commerce

No Exam

Exam

Detain

Clean Exam

How Does CPSC Review Shipments at the Ports?

Page 4: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

Seattle Safety Academy 2013

File Entry

Prior to Port At Port

Commerce

No Exam

Correctible

Exam

Detain Violative

Clean Exam

Clean Test

How Does CPSC Review Shipments at the Ports?

Page 5: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

Seattle Safety Academy 2013

File Entry

Prior to Port At Port

Commerce

No Exam

Failu

re to

Fix

Verify

Correctible

Exam

Detain Violative

Clean Exam

Clean Test

Fix Verified

How Does CPSC Review Shipments at the Ports?

Page 6: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

What is the Length of a Detention?How Often Does CPSC Detain Shipments?

Seattle Safety Academy 2013

ShipmentsEstimated number of shipments eligible for examination* 2,000,000Detentions 1,400Detention Rate 0.070%Average Detention Time 13.4 days

* - Entry data collection based upon pilot system product codes

Page 7: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

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.

Page 8: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

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

Page 9: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

How Did Shipments that CPSC Detained Enter the United States?

Seattle Safety Academy 2013

6%2%

6%

87%Samples

AirRailTruckSea

Page 10: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

How Often are Detained Shipments Found to be in Violation of a Regulation?

Seattle Safety Academy 2013

Shipments RateViolations 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)

Page 11: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

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%

SecondaryTracking 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.

Page 12: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 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

Page 13: 2013 Consumer Product Imports - Frequently Asked Questions, 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

Page 14: 2013 Consumer Product Imports - Frequently Asked Questions, 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

Page 15: 2013 Consumer Product Imports - Frequently Asked Questions, 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.

Page 16: 2013 Consumer Product Imports - Frequently Asked Questions, Safety Academy 2013

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

Page 17: 2013 Consumer Product Imports - Frequently Asked Questions, 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