littlethingsboutique says:
One note, BuggaLove. I wouldn't worry about retroactivity, as with the phthalates. The retroactive provisions for phthalates were already in the CPSIA as passed. When Ms. Nord and the CPSC tried to issue an exemption making the limits PROactive, the NRDC sued in the SDNY and the court ruled against the Commission. If there wasn't a provision for labeling to be retroactive, it shouldn't be stuck in at the last minute. (of course, this is Congress we're dealing with...)
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You're right! The issues are a little different with phthalates vs. labeling and I don't necessary expect that the retroactivity will change. I guess I'm just making general comparisons with last minute type changes/guidance to the latest issue at hand.
Here we are 6 weeks away from a deadline with very little to go on. It makes it extremely difficult to work toward compliance. And I don't want to sink money into labels only to find out they contain the wrong information or are the wrong shape/size/color...whatever it may be and have to re-do them. In the same vein, I can't wait too long to put my labeling plan into place as I can't afford to disrupt my business by not having the appropriate things in place. I'm sure we all understand to ramifications of the last minute decisions that have been part of CPSIA as each deadline rolls around.
I see that many people have read my blog. Thanks for reading, I hope it helps :)