These are the comments I submitted today:
I own a small business making fabric baby carriers. My sales, in terms of number of carriers sold, are in the hundreds each year, not the millions or even the thousands. Because of this, and because of my record-keeping, I can currently already pull up the name and address of anyone who’s ever bought a carrier from me, and I can sort that by type of carrier and date of sale. Soon, with CPSIA rules that go into effect in August, I’ll also be able to sort by date of manufacture.
A requirement to include a postage-paid postcard with every carrier would be overly onerous and costly to my business. I can absolutely see the need for this with major manufacturers, who largely do not have any interaction with their end user. On the other hand, small businesses like mine sell almost exclusively directly to the end user. In fact, I currently have more thorough information for my customers than I could ever hope to receive via registration cards, which do not have a 100% return rate. Each person who buys a Wallypop carrier MUST give me their name and address, at a minimum. Most smaller baby products manufacturers who sell direct to the customer work in a similar fashion.
Please consider, when making the final ruling on this aspect of the CPSIA, making exceptions for businesses that can already provide this information on demand. Perhaps requiring a postage paid registration card only if the manufacturer does not already have this information available to them.
This will fulfill the intent of the law, which is to ensure that manufacturers have the ability to contact their customers in the event that such contact is needed.
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