Comments on Third-Party Testing of Component Parts

Please accept the following comments from the Retail Industry Leaders Association (RILA) on behalf of our members in response to the Consumer Product Safety Commission’s (“Commission” or “CPSC”) Request for Comments and Information; Third-Party Testing of Component Parts; Section 102 of the Consumer Product Safety Improvement Act (“CPSIA” or “Act”). The issue of third-party testing of component parts is of the utmost importance to the retail industry and our suppliers. RILA believes that the language in the CPSIA allows certification of final children’s products to be based on testing of either the finished children’s product, or component samples that are identical in all material respects to the input material used on the finished product.


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