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Fact Sheet: Product Registration Cards

The National Association of Manufacturers opposed registration cards to protect children from dangerous products.

In 2003, the Consumer Product Safety Commission, the lead government watchdog over consumer products, rejected a petition to fix the ineffective product recall system.

Consumer experts, including the commission itself, have long known that recalls on even the most dangerous products were often ineffective. Most recalled products remain in the marketplace, despite media campaigns to publicize recalls. The petition, an attempt to examine the failure of the recall process, was blocked by industry and dismissed on a vote that included the rejection of the newly-appointed, industry-backed chairman.

In an effort to pull those dangerous products, the Consumer Federation of America had proposed that postage-paid registration cards be included with products for children. CFA noted in its submitted comments that children were the most likely to suffer harm from unrecalled, dangerous products and that such products made a good test case since they were already the subject of many of the Commission’s recalls. In the event of a recall, the contact information consumers returned could be used to directly warn them. CFA argued that direct contact would be more effective than relying on media alerts.

While CFA was supported in its petition by other public interest groups, including Consumers Union, U.S. PIRG and 25 state and local consumer groups, manufacturing interests, including NAM, were opposed to the petition. NAM, in its brief comments, noted that “child safety and recall effectiveness are issues of great importance to the business community.” However, its one page rebuttal of CFA’s petition did nothing to address the issue of recall effectiveness. Instead, the letter from NAM’s Associations Council Executive Director, Stephen Gold, dismissed the petition out of hand as a “burden on business.”

Rachel Weintraub, Director of Product Safety and Senior Counsel for CFA, explained in a discussion with Public Citizen that the scope of the petition was intended as a jumping-off point for negotiations on an ultimate rule. Some of the raised industry objections were dealt with in the petition. For example, the possibly expensive cost of postage was one such objection; but CFA’s comments called for the possibility of electronic submissions.

The deciding factor was the unwillingness of two of the three commissioners, including the recently appointed industry-supported chairman, Hal Stratton, to initiate a formal process that would have studied the issue. Dissenting Commissioner Thomas Moore, in his statement following the vote, wrote that he was “disappointed that we have not begun the formal process that I believe is necessary to give this issue the prominence it deserves.”

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