Dear NBVA Member: Much has happened in the short time since we furnished a Summary of the new CPSIA and a set of Frequently Ask Questions. The enormity of the administrative burden on multiple parties has become apparent by the hundreds of requests for clarification submitted to the CPSC. The staff cannot handle the burden and provide such individualized attention and therefore has streamlined some of the recordkeeping requirements, at least for a while. For example, the CPSIA, as passed, requires that the importer's certificate must "accompany" each product or shipment of products and the certificate must be "furnished" to each distributor, retailer (or operator) of the product. Presumably a "certificate" would be a piece of paper. Well, not any more. According to a Final Rule issued by the CPSC dated November 10, 2008: only the importer (not foreign manufacturer) must furnish the supplier's certificate; either a piece of paper (not likely) or an electronic form needs to be available when a shipment arrives in the US; the electronic form will be regarded to "accompany" a product if it is "available" to the CPSC for inspection at the time a shipment arrives if an electronic form is made available, it must have a unique identifier that can be accessed via a World Wide Web URL or other electronic means; among items required on the supplier's certificate is the date and place of the manufacture, but NOT the name of the manufacturer. Because of these very extensive changes, please disregard the prior mailings and refer only to the current attachments of the Summary and the Frequently Asked Questions. A comparison copy of each document is also attached to facilitate your review and understanding. Stay tuned since we expect more "clarifications" as the months go by. If you have more questions, please email me.