The US Customs and Border Protection Partners with the Consumer Product Safety Commission to Ensure the Safety of Imported Products
On October 29, 2008, the US Customs and Border Protection (CBP) announced the expansion of the Importer Self-Assessment Program to include the Importer Self-Assessment – Product Safety Pilot (ISA-PS).1 The ISA-PS is a partnership among CBP, the Consumer Product Safety Commission (CPSC), and importers to ensure product safety compliance.
By way of background, CBP (then known as the US Customs Service, Department of the Treasury) established the Importer Self-Assessment Program on June 17, 2002 to allow interested participants to assess their own compliance with CBP laws and regulations on a continuing basis. This trade facilitation program partners CBP with trade compliant companies to reduce Agency and company resources that are required during entry and post-entry. The program is intended to recognize and support those importers that have implemented internal controls to ensure compliance with CBP laws and regulations. According to CBP, since the program’s inception in 2002, the Agency has approved more than 172 importers under 760 different Importer of Record numbers to participate in the program.
The new ISA-PS is a partnership among CBP, CPSC, and importers to prevent the introduction of unsafe and non-compliant imports into the United States. To participate in the ISA-PS, an importer must (i) be an active and compliant member in the ISA; (ii) complete an ISA-PS/CPSC application; (iii) agree to comply with all laws and regulations administered by CBP and CPSC, including the Consumer Product Safety Improvement Act of 2008; (iv) maintain an internal control system that ensures the integrity of product safety; (v) notify CBP of organizational changes that may impact the importer’s product safety controls; and (vi) submit annual compliance reports to CBP.
Both CPSC and CBP must agree to accept an importer into this pilot program. If accepted into the ISA-PS, participants are eligible for multiple benefits, including the following: (i) a product-specific CPSC point of contact who can help provide National Electronic Injury Surveillance System (NEISS) Product Codes for entry lines; (ii) CPSC-provided training for product safety compliance, internal controls, and CPSC audit trails; (iii) the opportunity to receive external participation coverage of multiple business units; (iv) reduced product safety tests on imported goods; (v) priority testing by CPSC laboratories when product safety testing is conducted; (vi) acknowledged participation in CPSC’s “Fast Track Product Recall Program”; and (vii) destruction of products in lieu of redelivery to CBP.
CBP and CPSC currently are accepting applications from qualified importers who are interested in participating in this pilot program. Please feel free to contact any of the individuals listed below to discuss participation in the ISA-PS.
1 73 Fed. Reg. 64356 (Oct. 29, 2008).
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Georgia Ravitz
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James R. Ravitz
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Scott A. Cohn
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Amy S. Colvin
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Michael Sopko
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