Retailer Consumer Product Compliance Policy for Suppliers
(Direct Import and Private Label Products)


Summary

This retailer consumer product compliance policy template establishes standards and guidelines for suppliers to follow when providing consumer products to retailers who are (1) directly importing merchandise from outside of the U.S. and/or (2) selling merchandise as the retailer's owned branded product (i.e., "white-labeling"). This template includes practical guidance and drafting notes. Both of the above channels to the consumer market require heightened regulatory responsibility on the part of the retailer as compared to obtaining product from domestic suppliers without an intention to white-label the merchandise. This policy is limited to consumer products that are regulated by the Consumer Product Safety Commission (CPSC). The CPSC is an independent federal agency established to protect the public from unreasonable risks of injury or death caused by defective and hazardous consumer products. This compliance policy is designed to ensure that consumer products provided by a supplier to a retailer are high quality, safe, and compliant with applicable law. This policy includes guidelines for children's products, the CPSC's General Certificates of Conformity (GCCs), the CPSC's Children's Product Certificates (CPCs) product testing, supplier assessments, audits, and CPSC Section 15(b) reports (which must be filed when a supplier obtains information that a consumer product does not comply with an applicable safety or other rule or standard, creates an unreasonable risk of injury or death, or contains a defect creating a substantial hazard). For a general compliance policy not applicable to direct importing and/or white labeling, see Retailer Consumer Product Compliance Policy for Suppliers. For general guidance on creating a compliance program, see Compliance Program Creation and Creating a Compliance Program Checklist. For guidance on white-labeling, see Private Labeling.