That phrase comes up a lot when you are talking about product safety and compliance. Call me cynical, but depending on who says it, I give as much credence to a claim of “full disclosure” as I do when I hear the phrase, “with all due respect.” And, you KNOW what THAT means.
We continue to see more interest from larger end-user clients in sourcing promotional products that they are confident won’t damage their brands. The transparency clients are interested in means visibility into the complete supply chain. Where was the product made, and was it manufactured with an eye towards social responsibility and environmental impact? Does the product have the quality necessary to reflect brand positioning and, most important of all, is it safe for the intended use?
Josh Kasteler wrote recently on what he calls a first step towards more promotional product transparency. Josh, formerly quality and compliance manager at Gemline, and a past member of the QCA Compliance Committee, is now the principal at PromoCompliance. He suggests that “compliance questionnaires” being sent more frequently from clients to distributors is actually a very good thing. What may have been light reading in years previous is now given considerable weight with clients interested in protecting their brand. Speaking from the experience gained as a supplier, Josh says, “Those who do well will be at the top of the list for business and those who do not will be at the bottom, or cut altogether. Therefore, your answers to the questions need to be informed and backed up by documentation to impress. It sounds a lot like high school all over again – but you’ve got to show your work.”
We’ve talked before about the differences between dealing with product safety as a series of one-offs – such as testing only on an as-needed basis, or only when asked, and the development of a comprehensive compliance program. We like Josh’s point that knowing the answers to a questionnaire is a good first step, but also agree with him that living it as a basic business principle is the way to go. As he says, “Nothing beats having a well-developed compliance program with processes you use every day. These questionnaires 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.”
Leeton Lee, VP, regulatory compliance and general counsel at ETS Express, says distributors should learn of their clients’ specific safety and reporting requirements as early as possible to avoid potential surprises in the costing of an order. Suppliers need to make their own decision on whether to accept an order along with the additional specific compliance requirements required by the end-user. He adds, “Most good suppliers know their products and whether they will pass additional compliance requirements. Convincing suppliers that they need to meet end-buyers’ specific requirements can be difficult, especially when working with smaller specialty suppliers who may not have the knowledge, resources, or even the desire, to effectively tackle more complicated compliance needs of end-buyer clients.”
Can a potential new client tell from simply looking at your website where you stand on requirements mandated by the Consumer Product Safety Commission? Is safety and compliance a one-off for you, or is it woven it into the very fabric of your company and your daily business activities? Your corporate and social responsibility statement might well turn into one of the most important sales tools you have. And it could definitely afford a competitive advantage. When it comes to safety and compliance, the folks who are paying attention are the ones who stand to win in the long run.
Jeff Jacobs has been an expert in building brands and brand stewardship for more than 35 years. He’s a staunch advocate of consumer product safety and has a deep passion and belief regarding the issues surrounding compliance and corporate social responsibility. He recently retired as executive director of Quality Certification Alliance, the only non-profit dedicated to helping suppliers provide safe and compliant promotional products. Before that, he was director of brand merchandise for Michelin. As a recovering end-user client, he can’t help but continue to consult Fortune 500 consumer brands on promo product safety when asked. You can also find him working as a volunteer Guardian ad Litem, traveling the world with his lovely wife, or enjoying a cigar at his favorite local cigar shop. Follow Jeff on Twitter, or reach out to him at jacobs.jeffreyp@gmail.com.