While Congress enacted the Consumer Product Safety Improvement Act (“CPSIA”) in 2008, many of its requirements were stayed to give the U.S. Consumer Product Safety Commission (“CPSC”) more time to promulgate new implementing rules, and to allow product manufacturers, distributors, and importers more time to adapt their products and practices to the new rules. In 2011, many of the CPSIA regulations will finally go into effect, putting the consumer product industry to the task of complying with applicable regulations and giving the CPSC increasing grounds for enforcement. Businesses are well advised to keep up with the new requirements to avoid enforcement actions, both in recall and non-recall situations.

Below we have outlined a series of new requirements that are expected to issue in 2011, many of which are calendared for the year’s first quarter.