Mitigating New Product Recall Risks
In today’s competitive marketplace, new products are the lifeblood by which a company grows and prospers. And, while research has proven that speed to market is one of the key characteristics that help make a company’s new products successful in the marketplace, rushing the process may increase the potential for recalls later due to skipping or abbreviating key variables. Just as new products are a company’s lifeblood, product recalls can be a death sentence and are extremely costly in terms of lost revenue, legal fees, and damage to the company’s reputation.
According to government data, property damage, injuries, and deaths from consumer products cost Americans more than $1 trillion annually.
New Product Case Study
Lets say that your company wants to produce children’s clothing for 6 to 12 year olds. At a minimum, you would need to know the following:
RAW MATERIAL
What class of fabric do I have to use? (There are 3 classes of fabric under the Flammable Fabrics Act.)
HEAVY METALS
What is the allowable lead and phthalate content that may be in the buttons, snaps, and zippers?
TRACKING LABELS
Do tracking labels have to be affixed, and what information do they need to contain?
LAB TESTING
Does the product have to be tested and if so, by whom and under what standard?
DOCS AND CERTS
What type of documentation and certification is required and who should issue it?
By following best practices and carefully planning each step, companies can mitigate new product recall risks and ensure that new products are safe and reliable.
What Is a Product Recall?
A product recall is the process of retrieving defective and/or potentially unsafe goods from consumers while providing those consumers with compensation. Recalls often occur because of safety concerns over a manufacturing defect in a product that may harm its user.
Voluntary or Mandated?
A product recall may be voluntary or mandated by a regulatory body such as the Consumer Product Safety Commission (CPSC) in the U.S. From children’s products to ATVs to fitness equipment, there were 291 recalls in 2022 and 219 in 2021. During each of the previous five years, there were more recalls, ranging from 241 to 330 per year. Data from the CPSC show that there were more than 8,000 incidents reported in 2021 with more than 6,000 incidents involving an injury or illness associated with a product and 23 deaths reported in connection with the products recalled.
What does CPSC Stand For?
The U.S. Consumer Product Safety Commission (CPSC) is an independent federal regulatory agency that works under the Consumer Product Safety Act (CPSA), charged with protecting the public from unreasonable risks of injury or death from thousands of types of consumer products under the agency’s jurisdiction. The CPSC determines what products pose an unreasonable risk of injury and develops safety standards in accordance with its research on products. A recall can be initiated for noncompliance with existing federal safety regulations or to remove a product from commerce that poses a substantial safety hazard to the public. For a list of recalls, go to the CPSC site https://www.cpsc.gov/Recalls.
The Consumer Product Safety Improvement Act (CPSIA)
The CPSC administers the Consumer Product Safety Improvement Act (CPSIA) that was enacted in 2008 to improve the safety of consumer products. The primary provisions of the CPSIA include:
1) Limiting Lead Content In Products: The CPSIA limits the amount of lead that can be present in products intended for use by children, including toys, jewelry, and other products. The law requires manufacturers to conduct testing to ensure their products meet the lead limits.
2) Mandatory Safety Standards: The CPSIA requires the U.S. Consumer Product Safety Commission (CPSC) to establish mandatory safety standards for a variety of children’s products, such as cribs, playpens, strollers, and other items.
3) Third-Party Testing And Certification: The law requires manufacturers to have their products tested by a third-party testing laboratory to ensure they meet safety standards. Manufacturers must also obtain a certificate of compliance before they can sell their products.
4) Tracking Labels: The CPSIA requires manufacturers to include permanent tracking labels on certain products to help consumers identify the source of the product and facilitate recalls if necessary.
5) Database For Consumer Complaints And Safety Information: The law established a publicly accessible database for consumers to report safety incidents and to access information about product recalls. Saferproducts.gov was created to collect reports of harm or potential harm from consumers about unsafe consumer products, publish reports of harm or potential harm, and provide businesses with the ability and means to respond to reports about potentially dangerous consumer products.
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Reasons for Product Recalls
When looking at all recalled products and their associated hazards, we found that the three most common reasons for recalls in were:
%
PRODUCT COULD CAUSE INJURY
%
PRODUCT COULD CATCH ON FIRE
%
PRODUCT COULD CAUSE BURNS
There are many other possible reasons that a recall could be initiated. New technologies are emerging at breakneck speed and new products are appearing almost overnight. In their rush to get new products to market quickly, a product developer may overlook strategies mitigating new product recall risks, or be unaware (not an excuse) of existing regulations. Some other common reasons include:
- Manufacturing error
- Component failure
- New or unproven design
- New or emerging technology
- New product model with no safety history
- Noncompliance with mandatory standards
WHICH PRODUCTS ARE RECALLED THE MOST?
In terms of the types of products recalled, children’s products are typically the highest category, followed by furniture and related items, off-road vehicles, utility vehicles, ATVs, tractors, appliances, sports and recreation, bicycles and related accessories and electronics. Commonly recalled products include:
- Child safety seats
- Cosmetics
- Food
- Medication
- Toys
- Vehicles
The Recall Report is a database of US mandatory and voluntary product recalls. To search for a recall by product name or manufacturer or choose a product category below:
It’s the Law!
Federal law requires manufacturers and importers to test many consumer products, both for children and adults, for compliance with consumer product safety requirements.
Non-Children Products
Manufacturers and importers of general use products (i.e., non-children’s products,) for which consumer product safety rules apply, must certify in a written certificate that their products comply with those applicable rules. The CPSC has provided a model General Certificate of Conformity for use by manufacturers and importers as an example or form. A manufacturer or importer must certify in writing that its general use (i.e., non-children’s product) consumer product complies with all applicable consumer product safety rules or similar rules, bans, standards, or regulations under any law enforced by the Commission for that product.
Children’s Products
Federal law requires that every children’s product be tested by a third party, CPSC-accepted laboratory for compliance with the applicable federal children’s product safety requirements. The type of third party testing that may apply to an individual product may vary based on a variety of factors related to production choices. Companies should pay close attention to these mandatory testing requirements and maintain good records to document their compliance.
General Certificate of Conformity (GCC)
A manufacturer or importer must issue a General Certificate of Conformity (GCC). The GCC must be based upon the results of a test of each product or a reasonable testing program. The manufacturer or importer of a consumer product that is subject to consumer product safety rules or other standards is always legally responsible for issuing a GCC, even if a laboratory or another third party provides assistance in drafting the GCC. The CPSC has accredited a number of testing laboratories that can help companies make sure their products comply with all of the pertinent regulations. These testing labs are an extremely valuable resource for information and compliance.
The Development Robot
To find out if your consumer product is subject to consumer product safety rules or other standards, the CPSC has developed a very handy tool known simply as “The Robot” to help you identify important product safety requirements that may apply to your product, however, it’s based solely on the user’s input and does it replace or supersede a manufacturer’s obligations to comply with all applicable CPSC requirements. Nevertheless, its a very helpful tool and can be accessed at: https://business.cpsc.gov/robot/
Strategies To Mitigate New Product Recall Risk
Know Your Product
This is crucial for the product’s responsible party, whether it be manufacturer, distributor, importer or retailer. Companies need to know if there are any mandatory or voluntary safety standards that the product needs to comply with all along the supply chain. This may include product testing, which must be documented and certified.
Follow Industry Standards and Regulations
Companies should follow all applicable industry standards and regulations to ensure their products are safe and compliant. This includes conducting all necessary safety tests and obtaining any required certifications.
Use High-Quality Materials
Companies should use high-quality materials that are durable and free from defects. This can help prevent problems such as broken parts or leaks that could lead to recalls.
Conduct Thorough Testing
Before launching a new product, companies should conduct extensive testing to identify any potential issues. Testing should include real-world scenarios and be conducted under a variety of conditions to ensure the product performs as expected.
Implement Quality Control Measures
Companies should implement quality control measures to catch any defects or issues before the product is released to the market. This includes keeping production lot records, rigorous inspections, and testing throughout the manufacturing process.
Monitor Customer Feedback
Companies should monitor customer feedback to identify any issues that may arise after the product has been released to the market. This can help the company quickly identify and address any problems before they escalate.
Have A Recall Plan In Place
Despite best efforts, sometimes recalls are necessary. Companies should have a plan in place for how to manage any recalls quickly and effectively, including communication with customers and regulatory agencies.
In Summary
By following these strategies, and with careful planning and execution, companies can mitigate the new product recall risk and ensure that their new products are safe and reliable for consumers.
WE ARE PRODUCT EXPERTS WITH DECADES OF EXPERIENCE
At Bright of America, we utilize all these strategies and work with CPSC certified testing labs to give you peace of mind that your products will meet all applicable standards. Our product development experts are the best in the business and are ready to discuss strategies to mitigate new product recall risks and make your product launch a huge success! Contact us today to schedule a call to discuss your product development program.
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