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Stuffed Article Inspection Guide (Part 2) — License Violations

17
Jun

In Part 1 of our Stuffed Article Inspection Guide, we discussed the purpose of inspections, what inspectors look for, and what happens when an inspector finds an error with your product. 

Here in Part 2, we will dive deeper into one of the most common errors that can get your stuffed articles flagged by an inspector: issues with licensing held by the product’s manufacturer or importer. 

Table of Contents

Part 1 — What are Inspections?

Part 2 — License Violations

Part 3 — Law Label Design Violations

What are License Violations?

Before a stuffed article can be legally sold in the United States, the manufacturer of that product must register for and obtain licensing with the regulatory agencies where they intend to sell the product.

In certain states, importers are also allowed to register for licensing if they wish to list their company name and address on the product’s law label.

If there is a discrepancy with the licenses tied to the product, like if the license is expired or the URN listed is incorrect, it results in a license violation that can put the product at risk of fines or being pulled from store shelves.

Inspection Point #1: URN Validation

The first thing that the inspector will look at is the Uniform Registry Number (URN) listed on the law label under Reg. No. The URN is a unique identifier that ties the product back to the physical factory where it was manufactured.

The inspector will ensure that the URN is valid and active in their system. 

Inspection Point #2: The Company Listed on the Label

The next thing that the inspector will look at is the company that has their name and address printed on the label. Depending on how the law label was designed, it may say:

  • MADE BY — Manufacturer
  • MADE FOR — Importer, Wholesaler, Distributor, Retailer
  • IMPORTED BY — Importer
  • DISTRIBUTED BY — Distributor

Issues with the Manufacturer

The inspector will check that the company listed on the label matches the information listed on the URN license in their regulatory state / agency.

Issues with the Importer

In the states that require Importer (IMP) Licensing, inspectors will check that the product’s importer has an active IMP License in that state if they are listed on the label.

Inspection Point #3: The Designation and License

The inspector will also ensure that the correct designation is listed on the label’s “Manufactured By,” “Made By” or “Made For” field. This information must correspond to the type of licensing the company holds.

  • Manufacturer License — Tied to the company that physically manufactured the product.
  • Importer License — Tied to the company that imported or distributed the product for sale in the U.S.
  • Joint License — Tied to both the manufacturer and the importer or distributor.

There are several issues with the designation and license that may cause a law label to be non-compliant:

Incorrect Match

For example, a law label that says MADE BY and then includes the retailer’s name and address would be found in violation.

Incorrect License

If the law label says MADE FOR [Importer] but the importer does not hold an Importer License, that product will be found in violation as well.

Lapsed License

Licenses must be renewed in each state to remain compliant. A lapsed license will also cause the product to be found in violation.

Keep Your License Current

Staying on top of your license renewals as a manufacturer or importer has a direct impact on your product’s standing with inspectors. Whether you need help registering for a license for the first time or you need help staying ahead of expiration dates, GRS offers full support for licensing. 

Learn more about our Monitored Services, and keep your licenses active to stay in good standing with the inspector.

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