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ARTICLE · 11 NOVEMBER 2024

Let's Circle Back (And EFile) After The Holidays

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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The Consumer Product Safety Commission launched its eFiling Beta Pilot a little over a year ago. Non-pilot participants were invited to participate in voluntary eFiling last summer, and the CPSC...

United StatesConsumer Protection
Sherwet H. Witherington
Sherwet H. Witherington
Charles Samuels
Charles Samuels
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The Consumer Product Safety Commission launched its eFiling Beta Pilot a little over a year ago. Non-pilot participants were invited to participate in voluntary eFiling last summer, and the CPSC extended this stage to October 10, as it continued to work on a revised rule. The CPSC had anticipated completing a final rulemaking by the end of its fiscal year, which would have meant a full system implementation around January 1, 2025 - but regardless of when the final rule is published, the CPSC has proposed that the requirements go in effect 120 days after publication in the Federal Register.

Notably, the National Association of Manufacturers submitted comments regarding the rulemaking, highlighting issues with the proposed rules, including the scope of the filing system, technical and financial burdens for implementing the system, and the feasibility of complying with the proposed 120-day effective date window. It remains to be seen whether the CPSC will take

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