Request for Information: Counterfeit Certification Markings

The Household & Commercial Products Association (HCPA) supports the CPSC's efforts to understand and address the risks posed by counterfeit certification marks. They argue that these marks mislead consumers, harm legitimate manufacturers, and erode confidence in safety standards, particularly within online marketplaces.

IAPMO, a global product certification agency, submitted comments in response to the CPSC's Request for Information on counterfeit certification marks. They highlight the significant safety risks and financial costs associated with counterfeit marks in the plumbing and mechanical sectors and offer to provide technical expertise and specific examples to the CPSC.

UL Solutions supports the CPSC's efforts to hold unlawful actors accountable for counterfeit certification marks, noting that such marks pose significant safety risks to consumers. The company highlights its role in the safety ecosystem and advocates for an all-of-government approach involving enhanced information sharing between the CPSC, CBP, and other agencies to deter counterfeiters.

The Association of Home Appliance Manufacturers (AHAM) supports the CPSC's Request for Information, emphasizing the significant health and safety risks posed by counterfeit appliances and deceptive certification markings. They urge the Commission to lead coordinated federal enforcement efforts, improve inter-agency data sharing, and launch public education campaigns to help consumers identify and avoid counterfeit products.

Consumer Reports, an independent nonprofit organization, supports the CPSC's efforts to address counterfeit and misleading safety certification markings. They urge the agency to prioritize these issues for children's products and lifesaving devices, and to coordinate more closely with e-commerce platforms to improve oversight of third-party sellers.

The Water Quality Research Foundation (WQRF), a nonprofit organization, supports the CPSC's focus on counterfeit certification markings for water filters. They provide research data demonstrating that counterfeit filters fail to remove contaminants like lead and can actually introduce harmful substances into drinking water.

The National Electrical Manufacturers Association (NEMA) provides detailed information regarding the prevalence, risks, and economic impacts of counterfeit certification markings on electrical products. They urge the Commission to prioritize enforcement, strengthen coordination with certification bodies and e-commerce platforms, and increase consumer awareness to protect product safety and market integrity.

The commenter submitted a highly incoherent and rambling letter containing various legal citations, conspiracy theories, and personal grievances. The text does not provide a clear position on the proposed action regarding counterfeit certification markings.

The commenter suggests that implementing a product number system would improve the detection of counterfeit certifications. They argue that this system would allow for the creation of a comprehensive product database and enable various agencies to verify product authenticity.