Comments on Section 217(b)(2) Civil Penalty Criteria

Please accept the following comments from the Retail Industry Leaders Association (RILA) on behalf of its members in response to the Consumer Product Safety Commission’s (“Commission” or “CPSC”) Request for Comments and Information; Section 217(b)(2), Civil Penalty Criteria, of the Consumer Product Safety Improvement Act (“CPSIA” or “Act”). Section 217(b)(2) of the CPSIA directs the Commission to issue final regulations interpreting the penalty factors described in section 20(b) of the Consumer Product Safety Act (15 U.S.C. 2069(b)), section 5(c)(3) of the Federal Hazardous Substances Act (15 U.S.C. 1264(c)(3)), and section 5(e)(2) of the Flammable Fabrics Act (15 U.S.C. 1194(e)(2)), as amended.