Product stewardship is the responsibility of manufacturers to manage the health and environmental impacts of their products throughout the lifecycle of raw materials sourcing, production, consumer use and disposal. The concept has taken on added importance as supply chains for domestically sold products stretch back into parts of the world with laxer health and environmental standards and weaker enforcement. U.S. product regulation is now being used as a lever to elevate environmental, safety and health (ESH) practices in the developing countries that supply our marketplace. 

The importance of product stewardship was spotlighted in 2007, during what has been termed “the summer of recalls.” Importers of children’s toys and jewelry containing excessive lead, along with importers of melamine-tainted pet food, were subject to high-profile fines and recalls. In the process, long established and trusted brands were tarnished, and Congress moved to enact the first major overhaul of consumer product safety laws in three decades. The Consumer Product Safety Improvement Act (CPSIA) established tough new requirements for conformity assessment and labeling, as well as third-party testing of children’s products.

A demand for product stewardship is reflected in other recent regulations. The California Air Resources Board (CARB) has phased out the use of urea formaldehyde in particleboard and other composite wood products sold in that state, and federal authorities are in the process of applying that prohibition nationally. Congress has also tightened the scrutiny of imported products containing wood to ensure it was sourced from legal timber. The Lacey Act Amendments require that customs declarations specify the species of wood, where it was harvested, and the proportion of renewable content.   

In 2010, Congress began work on a rewrite of the Toxic Substances Control Act (TSCA) which is expected to substantially increase the data on health effects that must accompany chemicals brought to market in the U.S. It is likely the revised law, when finalized, will resemble Europe’s REACH law, which requires producers of high-volume chemicals to identify the chemical’s toxicity, persistence and bioaccumulation, along with lifecycle impacts and safe handling instructions.  

The Sapphire Group is well equipped to advance your product stewardship efforts. We will work with you from the early stages of product design to identify environmentally superior materials and processes. To ensure conformity with the tangle of U.S. product laws, we can design sampling plans, identify reputable testing labs, and manage compliance documentation. For those clients ready to enhance their brand by rising above governmental mandates, we have extensive experience with the precautionary approach embodied in programs such as REACH, HEDSET, TSCA, and VCCEP.

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