Argh. CPSC’s Final Rule on Baby Slings
So… The CPSC has issued the final rule about Durable Nursery Products. Baby slings are, for the first time ever, defined as a Durable Nursery Product in this ruling. That’s bad, folks. Bad.
It means that I will need to start including a product registration card with every sling that I sell starting in December of 2010.
This means that I need to get cards printed up (shouldn’t be a big problem, I can make them myself and have Office Depot copy them for me, but it is an additional expense). I need to stamp them. I need to track them as they come in, log them into a database, and store them somewhere.
Not necessarily a huge deal, though it is more time and hassle on government regulations. And definitely expense in both postage and time. I’ve absorbed a LOT of the increased time cost related to CPSIA so far, but there’s a point at which I just can’t absorb it any more. I’ve reached that point.
But what bothers me more is that I don’t see any way around having to start packaging my slings. I have so far avoided packaging them for several reasons. First, the idea of having disposable packaging around my products just really bothers me. I know most “name brand” diaper and sling makers use disposable packaging, but, well, I’m not them. Second, the packaging just represents an additional cost which would need to be passed along to the consumer.
Packaging goes against the two main driving forces behind Wallypop – reducing waste, and cutting out unnecessary expenses in order to keep prices as low as possible.
I’ve got a year to figure this out, obviously, but as I work on packaging and including cards, I’ll more than likely need to put in a price increase on baby carriers. This makes me very sad, because of the overwhelming number of emails I’ve received since opening from customers who were discouraged because they were having trouble finding quality babywearing products in their price range. One woman wrote, “until I found Wallypop, I was afraid my choices were the bad-looking slings of dubious quality that I could afford, or buying something that was out of my budget.”
Darn you, Congress!!
And there’s always the chance that the CPSC will clarify and we’ll be able to do electronic registrations, which would be nice.
PS, I posted my comments to the CPSC during their request for comments phase on here earlier. My point remains valid. I have more information on who has purchased what sling than I could hope to ever receive via product registration. 90% of my slings are sold direct to the end user, who has had to give me their name, address, phone number, and email address. I can pull up a list of everyone who’s purchased a ring sling from me since I opened, then peek in to their invoices and tell you exactly which one was purchased by each customer. That’s for 100% of my retail sling sales. That’s waaaay better than any product registration card system.
I’m also willing to bet that my sling retailers have this level of detail on THEIR customers, meaning that the 10% of slings that I sell wholesale are also trackable. More trackable than through registration cards.
Incidentally, in researching this further, I found that in 2001, the CPSC considered requiring a product registration card for every item sold for use by/with children. Fortunately, they decided not to proceed. Can you even imagine? I’d bet that such a law would actually reduce the number of parents who bother to fill out registration cards for the important things like carseats, etc.
Also, not for nothing, but the inclusion of slings as Durable Nursery Products can only mean trouble from here on out. Durable nursery products have stricter regulations than most other baby products. Not good, not good.