It started with such a simple and noble objective – protecting children from lead and other toxins.

Remember the millions of Barbie® Dolls recalled in the summer of 2007 for too much lead in the paint?  That was the catalyst for the Federal law we all know of as CPSIA.  But what we ended up with is anything but simple.  Even CPSIA experts have a hard time agreeing about what is or isn’t a children’s product under Consumer Product Safety Commission (CPSC) guidelines.

At PPAI’s recent Product Safety Summit in Denver, I projected images of several products and asked attendees to raise their hand if they thought the product was a children’s product.  The first image was a simple water bottle for a first grade Little League team.  The imprint said “Meadowbrook Little League” in bold Helvetica type.  The second image was the same bottle with an imprint of Dora the Explorer.  One is considered a general use product, one is a children’s product.  Same bottle, same lead content, different imprint.  Both are going to be used by the same 6 year old kids.  One requires testing and must comply with CPSIA requirements.  One doesn’t.

These examples go on and on.  They make you scratch your head and wonder what happened to that simple noble objective.  At the Summit, our featured speaker was Mary Toro, head of regulatory enforcement at CPSC.  Even Mary wasn’t sure whether some of the products we showed would be considered children’s products.  It’s complicated even for the experts.

How did this happen?  Another noble objective gone awry.  In trying to please the varied constituencies, CPSC came up with a compromise:  If a product appeals mostly to young children, it’s a children’s product.  If the same product appeals equally to everyone, it’s a general use product.  Helvetica lettering apparently appeals to everyone, Dora doesn’t.

But is it a good thing that certain products can be sold for use by young children without having to comply with child safety laws?   Not for the promotional products industry.  The risk to our customers is too great.

Consider this:  If a product is going to be used by children – a general use product that is to be used by all ages – how would it play in the press if it was revealed that the product was full of lead or cadmium or phthalates?   What embarrassment could that cause your customer if it became viral on the web or, heaven forbid, the subject of a Keith Morrison exposé on Dateline?  Can you imagine the phone call you would get asking how you could have put the company in that position?

Two recent cases illustrate how toxins in products can have a devastating impact on a company’s reputation – even if the products are compliant.  The first is McDonald’s costly Shrek glass recall and the second involved reusable grocery bags containing lead from Publix, Safeway and others.  Each involves products that may have been technically compliant in a court of law but not in the court of public opinion.  Each involved millions of dollars in negative publicity in addition to the millions spent in recalling the glasses and bags.

The message is clear:  As fiduciaries of our customers’ most valuable asset – their good name – let’s make sure we’re selling products that meet the CPSIA limits for lead and phthalates regardless of whether the product is technically going to be considered a children’s product or not.  In addition to protecting our customers’ good name, we’ll be protecting our own future.  Remember: Large corporations are risk averse.  It wouldn’t take many high profile fiascos for these businesses to decide that promotional products are too risky.

Insist that all products you sell – and particularly those for which children may be involved – are compliant with the new 100 ppm lead standard and all other applicable provisions of CPSIA.

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