PPB April 2016

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64 • PPB • APRIL 2016 THINK
PRODUCT RESPONSIBILITY
backed up by documentation to impress. It
sounds a lot like high school all over
again—you’ve got to show your work.
Your questionnaire grade translates to
how risky your company appears to your cus-
tomer, and that amount of risk will dictate
the level of business they give you. Those
who get a poor grade will be considered risky
and it can be a long, uphill battle to change
that. In some cases, risky vendors are required
to undergo expensive audits and other
improvement schemes in order to get back
into good graces.
Here are some guidelines to help you
prepare for the next customer questionnaire
that lands in your inbox:
PRODUCT SAFETY The last thing your cus-
tomers want is to have their brand placed on
a dangerous or recalled product. Here are a
few fundamentals they will look for:
• Product Assessments Do you have experts
to evaluate new products before you pur-
chase or develop them? Do you anticipate
any hazards with those products and, if so,
do you have a testing program to check
them?
• Testing Can you provide recent test reports
to confirm the products don’t contain any
regulated harmful chemicals? Can you
track the testing to the actual product lot
from the factory?
SOCIAL COMPLIANCE Today end users
increasingly want to treat your supply chain as
part of their own. Here are a few must-haves:
• Code of Conduct Do you have a code of
conduct and require that all suppliers sign
it? Is it implemented up the supply chain?
Does it meet the industry standards of
organizations like the Fair Labor
Association and other major consumer
brands? (You can adopt the PPAI Code of
Conduct as a good first step. Find it at
• Factory Audits Can you show that your
suppliers have had at least one social com-
pliance audit in the past year? Was a third-
party laboratory and/or industry standard
used (e.g., Sedex)?
COMPLIANCE Your customers will expect
that you have the complex and confusing
world of compliance regulation all figured out.
• Regulation Do you have statements on
your website that summarize your compa-
ny’s approach to the Consumer Product
Safety Improvement Act (CPSIA) and
Prop 65? Can you tell your customers the
testing that is necessary for a product type?
Is your staff trained on Undue Influence
and Recall Management?
• Documentation Can you provide
General Conformity Certificates (GCCs)
and Children’s Product Certificates
(CPCs) upon request? Can you show that
a product was properly evaluated, tested
and inspected before shipping to your
customer?
The steps above are just a start, but hav-
ing this information ready will make your
next questionnaire request much easier and
more impressive. Of course, nothing beats
having a well-developed compliance program
with processes you use every day. These ques-
tionnaires can actually be a good thing as
they can lead companies down the road to
creating an effective program to ensure all of
their products are safe and compliant.
These types of documents are all part of
the larger push for transparency in our indus-
try. For decades we’ve kept our supply chain
secret but this practice is largely incompatible
for larger customers. The questionnaire is the
first step to have more transparency in the
process, but it’s going to go deeper as time
goes on. Expect more audits, more documents
and more expectations from your clients.
On a positive note, receiving a compli-
ance questionnaire is an achievement—it
means you’ve made the initial cut of vendors
and your customer wants to learn more about
you. It also means there is an opportunity to
do a better job than your competitors. Their
loss will be your gain.
Josh Kasteler is a compliance consultant with PromoCompliance. He can be reached at .
PPAI’s Promotional Products
TurboTestTM provides a product
safety road map, asking users
simple, yes-or-no questions about
a particular product or product
line and then breaking down the
relevant product safety regula-
tions into easy-to-understand,
easy-to-implement steps. It’s fast,
easy-to-use and free to PPAI
members. Take a look. Find it
under Inside PPAI/Product
Responsibility at .
Compliance Tip: