 Good morning everyone Welcome to CPSC's public meeting on the e-filing alpha pilot. I appreciate everyone's patience while we were Getting ready and getting started this morning like to welcome everyone My name is Jim jahoski, and I'm the deputy director of CPSC's office of import surveillance shortly, we're going to do introductions of The CPSC staff participating in the meeting as well as all of the importers and brokers that are either in person here in Bethesda at our headquarters or on the phone And we appreciate again everyone's attendance and and you're volunteering to participate in the pilot Before we're getting further. I'd like to invite chairman le k to give some opening remarks There we go. Good morning everyone. I took off my jacket in part because I really want everyone to have a very Comfortable experience here and to really open up and to have a dialogue that goes back and forth about this experience This is a really important endeavor for us, and we're very very grateful For each and every one of you for your participation It has really made a big difference, and it's been a huge public service And I really I mean that with all sincerity This has been an incredible lift for the United States government as many of you are Intimately aware and we're not doing this alone. We have been doing this in conjunction With the 46 other agencies that have border authority to try to create that streamline single window That is now finally online. It's got a long way to go a lot more enhancements are planned for it But the point is to make this easier to facilitate trade to better target our resources As I think you would want us to be doing on those who are non-compliant And to make it so that there's just better communication that when holds are put on Goods, you know why you know who's done it, you know what what the purpose is You know what the timeline is and you know who to interact with and there can be a good communication back and forth So our part in this was really to get this alpha pilot going to test the plumbing to see if we can get Something off the ground an electronic filing system in a rudimentary form Provide the registry to make it as easy as possible I think there's a brilliant idea with our staff and the contractors to come up with to try to make it so that you can just Have one number that allows us to pull from that registry any data that you put in there and We feel like and I'm sure Jim and the team will go through it We feel like it's has gone very well But we of course want to hear your feedback the good the bad and the ugly Because it was just an alpha pilot and the plan is to do a beta and to take it to the next step And your help and your participation in that and I hope you'll continue is going to be vital to trying to get it to be an even better system Clearly we're going to be going through a transition here like the entire government is going through and There will be different priorities by different leadership at the agency at some point this year My hope though, especially while the current composition of the Commission is the same is That we will continue this effort and that we will do our part to be part of that single window as envisioned I don't think it's good for anybody for CPSC to fall off and for the government the rest of the government and the rest of the agencies to move in one Direction and for us to stall out. I don't think that serves anyone's purpose And so my hope is that even with leadership change that you'll continue to be vocal You'll continue to be present and you will express your interest It with the CPSC Continuing to do its part to be part of the streamline process So I don't want to take up any more of your time. You're definitely not here to listen to me nor should you be I Hope you don't mind. I'll sit in the back and just hear some of the discussion because I really am very interested in it And I don't I hope you don't hold back. I hope you let us know this only works and it only gets better If you give us your full and candid feedback, so thank you very much and thanks Jim Thank you So I wanted to talk about talk briefly about sort of our agenda for today I'm gonna gonna kick it off by by reviewing a brief PowerPoint presentation Providing some background on the on the alpha pilot So our our volunteer participants are are gonna know this information very well But the slides will provide some basic background for those that may not be as familiar with the with the pilot Then we'll get into the main reason for the meeting and where we will spend most of our time Which is to hear from the participants and better understand understand their experience In the pilot We plan to organize today's discussion around five topic areas. We want to talk about data We want to talk about the product registry Broker interaction with the importers the filing process And then recommendations for the future Due to time limitations Excuse me. We we plan to be done here by by noon today We're gonna limit the discussion on each topic to about 25 minutes We'll also stop about halfway through for for a 15-minute break If time permits we will also try to answer any questions from Those in attendance here or anyone watching on the webcast and those questions can be sent to e-filing pilot at cpsc.gov So before we go any further like I thought it would be good so that everyone could kind of identify themselves and Perhaps we could just start with cpsc staff real quick again. My name is Jim jaholsky I'm the deputy director of the office of import surveillance I'm Lisa read Miller, and I've been the project manager on the e-filing alpha pilot So the shoppers good dressed guy in the room is obviously the IT guy So my name is Ming Jun from the office of information technologies John will share international trade specialist import surveillance All right, great. Thanks everyone and So why don't we go with they go around and the participants can identify themselves? Fishman and Tobin Bob Hammett logistics and customs compliance Brittany Carrington complex compliance and logistics I'm Keith Corkdale. I'm director of product safety Fruit of the loom Russell Brands, would you like to introduce yourself? Yeah, this is Charles Sanders responsible for custom trade compliance, and then on my team I have Tara Hoss and Amber Trannum. We also have ripped in this from a quality department as well the John Dury Christine will Ikea On the phone from Sweden Magnus Björk What can we do for our compliance? Good morning Sorry, April Ikea customs and compliance for North America Mizuno Amy cross Customs compliance manager and blended running analyst Great, thank you Procter and Gamble on the phone We have customs compliance and regulatory James Craley Nancy irons and Dan Gamble and with us are our import partners expeditors Cheryl Johnston and Callie Colton Great. Thank you 7th Avenue Very equal sir and bill shockers Right. Thank you Walmart. I'm Ken Henson with product safety and compliance I'm Jennifer Horner with our direct import customs team. I'm a director of compliance and regulatory audit And then on the phone Kara Rose with product safety decline Great. Thank you Moving to the brokers that participated border brokers Yeah, so on the phone Renee Borreira. Good morning Good morning. I know expeditors Good morning. This is Ian Smith. I'm the senior manager customs compliance for our us and brokerage Customs operations And Geotas Hi, this is Chris Alonzo. I am the director of customs brokerage for Geotas Great, thank you So now I'd like to just move into some oh, I'm sorry did I interrupt someone Good morning, Jennifer So what I like to do now is just run through some quick slides just to kind of level set and give some background On the pilot. So what was the pilot? This was a joint effort between CPSC and CBP to test electronic filing of Certain targeting enforcement data It was a test conducted with a small set of volunteers that are all participating in this call Who really did work collaboratively with us in CBP to make this what we feel a successful pilot and We came up with a two-prong approach to collect the data And I'll talk about these in just a little bit more detail and subsequent slides, but a Full mess a full PGA message set and then the reference PGA message set Using the CPSC develop product registry So for the full PGA message that this was a fairly straightforward way of providing the data The filer would file the the five pieces of additional information for regulated products along with The other required information That CBP would ask for as part of the normal filing and that information would Flow through CBP to CPSC and be available in our internal RAM targeting system the reference PGA message set Required that that the product information be filed in the CPSC product registry in Advance of submitting an entry Via the PGA message set so this reduced the amount of information that brokers needed to file because as the information was filed in the registry the The importer would receive a reference number and as part of the entry filing The reference number was the only piece of information the only additional piece of information that needed to be filed with CBP and Again, we would receive all of that information And match the entry to the information in the registry and bring that information into our RAM system some of you may remember if you've been following sort of our progress on electronic filing that in 2013 in May of 2013 the staff had actually Was working towards and proposed To have certificates of compliance electronically filed so all the information that was required on certificates of compliance To be filed electronically Based on a lot of discussion and feedback From stakeholders the Commission ultimately decided to limit the e-filing alpha pilot to four data elements from the certificate And then a checkbox that would just indicate whether or not a certificate Was available if we were to ask for for full certificate information the scope of the e-filing alpha pilot was very broad in that We opened it up to any product that was regulated by CPSC as well as three products that are on the 15j substantial product hazard list and those three products were hand-supported hairdryers extension cords and seasonal decorative lighting products holiday lights as I mentioned they there were Five pieces of information required for regulated products. So in addition to the checkbox The volunteers were asked to provide four pieces of information from the certificate and those were the Identification of the finished product each applicable product safety rule To which the product is certified the place of manufacture including the identity and address of the manufacturer and The name and contact information for the testing facility on which the certificate depends For 15j products for the hairdryers extension cords and holiday lights the information There were only two pieces of information that we asked for and that was an identification of the finished product And then the place of manufacture including the identity and address of the manufacturer So we had several goals going into the alpha pilot and we're really Hoping as part of this discussion today that we're going to see where we are as far as meeting these goals So one of our goals was to partner with CVP in the industry to collect the required data elements using the CPSC PGA message set We wanted to assess whether the importers were Able to provide additional data in advance of importation We wanted to test our technical solution including the the registry and we wanted to evaluate the differences between the Product registry and the reference PGA message set and then the full PGA message set What were the pros and cons of both of those ways of providing the the additional information? We wanted to identify any issues and implementing e-filing as well as the the burden the costs and they're in the and the The time and the costs associated with filing the additional information and we wanted to be able to inform the Commission on possible options for Moving forward in the future with with e-filing and so on this point Just to kind of let you know where we're staff is Heading with this so After this meeting we We will continue to evaluate the data that we received as part of the e-filing alpha pilot And we will be preparing an evaluation report for the Commission on the outcome of the alpha pilot As part of that report We are also planning to provide the Commission with what we see to be the options and moving forward with a beta pilot and A staff recommendation as well There's just some brief high-level Stats from from the from the pilot which we stopped collecting data as you know at the end of December So we had a little over 1200 products that were entered into the registry I'll based on those 1200 products. There were over 15,000 PGA message sets that were filed 99% of those were reference PGA message sets Involving the use of the registry so I mean clearly from just that high-level information it appeared that the registry was something that that the That the volunteers felt was was a useful way of moving forward We had a very small number of errors less than 1% and Of the of the products that were the shipments that were entered under the pilot they the country of origin We had 12 countries of origin different countries of origin and they came in through 15 ports of entry So thank you for for your patience as I just sort of ran through those that that background information so now What we'd like to do is kind of me stop talking and start to hear from you all So our first topic that we wanted to Get into is data and I'm gonna invite my colleagues here to to jump in with questions with comments as well and What we have here as far as questions are just a starting point We don't necessarily have to follow these you know This is sort of to get the conversation rolling But as far as around these topics we'd like to we'd like to hear from you and we'd like to kind of understand Better what your experiences were in these so I mean just I'll just sort of kick it off with if If you could just elaborate on your ability to gather the data that was required And and along with that, you know, we're there where there are certain data elements that were easier or harder To to compile we were interested in that and I'll just sort of open it up for those here in the room I think we have a limit of a five microphones that can be hot at any one time. So just if you're not talking if you could Just just silence your mic and you know, we we invite everyone on the phone So I'll just sort of open it up. If anyone would like to start the conversation Hey, Jim, this Ken Henson from Walmart You know as to the first question kind of the ability to gather the required data For us that the the ability was easy It was it was quite easy for us to gather the data. We already have it maintained in a in another third-party system So for us, it was just a matter of going in searching extracting the information we needed for the registry You know, not surprisingly the challenge around that is is is the resources required to do it And we've talked about this before, you know from our standpoint There has to be some sort of automatic automated solution But because it really is a manual process for us at this point when our when our third-party system Was was designed and created? It was never with the intention to to have a feed of that information going to our brokers and then Or into the into the cpsc registry. It was always just a As much a data warehouse as anything With search capabilities so that if we were asked for Certificate information we could go in and search and provide it to the cpsc in a timely manner, but But but that that functionality was never intended to be done hundreds of thousands of times You know a year, which is what it would amount to As a full as a full implementation of this program So the ability was easy, but but the resources for us would would be would be really high Okay, Magnus Björk Ikea We had the data in our own system already. So the collection of the data was easy And we actually decided to build the automated version of this As a part of the pilot to understand more what it took from our organization internally And The only thing that we could see I could see that was a little bit tricky is that We have typically the Identification of the seller on our information and we were expected to provide the manufacturer and that part we Didn't actually build in this trial version of the pilot but And it took some time to do them To create the data feeds and we had some issues internally, but All in all it was good that we did it because we Learned a lot. This is Laurie Magnus Just to echo a little bit about what Ken had said and then to follow up a little bit on what Magnus had said So yes, we did we did use our internal data that we used to generate the GCOC and we I think our problem is we decided not to do it manually But we decided to integrate as part of the pilot so tying the GCOC information in our database to our entry Systems our customs declaration systems. I think is where we stumbled a little bit But it was a good exercise as Magnus had said Because that started to highlight for us what we had to do to bring The the testing data and all the GCOC data to the specific shipment that we were making in Trion And I think the other thing as Magnus has said is we do have some limitations on the actual manufacture When it is different than who we're buying merchandise from our customs declaration system has that capability to do that But the interface was not there. So that piece was manual. We had to manually type that in for each entry So that we could make that work Bob have it fnt We had no profits at all, you know collecting the data I think on the challenges on the brokers end a little bit with regards to transmitting at the cpsc Through the entry setting up the the files We basically set a common delimited file into the broker were just a registration number tagged on the end of it It was you know applied to the entry and and transmitted off. So there was no Nothing cumbersome on our end or high expense that was incurred Just a few hours of programming work We basically manually keyed the stuff into the registry and then attached it to a style number that was kept in our system And then when we called up that style number to be entered It was attached to the transmission and sent over to the broker. So there was a not a lot of Not a lot of you know cost or a heartache on our end However, I will say one more thing and that's in a production environment that we are doing it One thing comes to mind and we'd like to know what the commission's Failing is on component testing with regards to end product testing And a manufacturing environment. So if we were testing buttons and zippers and various items that went in on a component level As the pilot moves forward they're going to expect finished product testing As a requirement for the the end use of the product or at the end result of the product for the registry So I think on that note So the pilot was set up really to Only focused on on the finished product itself the certification related to the finished product So I don't I don't see us varying from that perhaps in the future That would be perhaps something that the commission may need to weigh in on but I think we would continue to look at The finished product that that's been certified Jim I think it's I think it's somewhat telling that you know Magnus and Laurie and then Bob and myself all kind of You have a brief description of the way we went about it and and we were all different I think that's going to be part of the challenge too. And that's one of the takeaways is I think every every Participant in this and probably in the beta pilot and then in full implementation It's going to have a little bit different approach to this And so when we do start talking about automation and finding those systems and things that could be really difficult to find something That's going to meet everybody's needs Just the three of three different groups four different groups here in the room all Tackled it a little bit different way because of how their systems were already developed And so trying to find you know trying to find something that's going to plug into that that's going to work for everybody I think could be a real challenge Yeah, well, I think we'll have to rely on our our technical folks here to to sort of work with and and understand kind of what what are some of those different ways to try to Um, you know if we were able to move forward with a beta how How we can design something that would that would be as universally Applicable as possible, but I agree. I mean it sounds like everybody is doing it has done it a little bit different Just with the eight companies that are that we're participating I can mention that our system is basically built on the logic now that When you when we create the normal sophisticated compliance This is created in background automatically So we have one task in that it's create this certificate of compliance and um, The rest of it happens without the use or seeing it one thing that I wanted this is uh, charles is through the loom. I wanted to know that uh We we took a very small sample of our overall product universe Program and we work closely with our quality team because we tell some of the data for customers to trade compliance To provide the broker. Unfortunately We're already providing the manufacturer information because we are an apparel company to the customer broker and to u.s. Customs And then we got the other additional information from our quality team So that information is currently stored in two different locations And we just had to bring it together, but it was easy to bring together for the pilot But it will be undertaking for us to do the Complete universal product that we have Um, this is Jennifer from walmart. Um, one thing I wanted to add to in relation to the It's it's not just about design, but it's also about volume um We tested two tariff codes two toy tariff codes and toy is our primary import direct import of the two tariff codes that we tested um, we had over the last year 44 48, I'm sorry 48 thousand entries On those tariff items that would have to be culled through your system in order to And that's just two given the depth and breadth of our product line And what we hit within the tariff. I mean we're within 88 chapters of the tariff book And some of the items that you're looking to test, you know, you have whole chapters that you Encompass understandably so but It's just the point is that you know with two tariffs and 48 thousand entry lines You know expand that to include All the chapters that you're that you have to cover from a cpsc perspective And I think that compares with the 100 or so entry lines that we that we have for the pilot Yeah, just for the two tariff codes So the 48,000 number is a spread across five ports We had two ports that we used in the test phase um, and we only did What was it a hundred and or we only entered 62 products into the registry so one of the things that We were talking about was Would there be an option for us to I know that you have the registry option And then you have the entry option, right? Getting obviously that 48,000 isn't they aren't unique individual products that 48,000 translates to 3,300 individual products So for us that entering that 3,300 into the registry and having that Data cult, you know that expands out into multiple purchase orders multiple entries You'd be looking at the same things over and over and over again So it would make more sense from our perspective to cull it Down to the product level maybe just looking at it through the registry itself and then Coming back to us at that point in time as needed Yeah, that's that's the benefit of the registry is is definitely the expectation is that on a product basis, especially for a lot of large Companies that you're going to have repeated Filings that are going to be necessary as you're coming through so why not post at once and just state With a single id and also on our end If we're able to match up our exams on a particular id number I've tagged you once on that product. I'm done as well if it's clean So we can track that much more effectively as well and get out of the way and that's that's part of this process as well So under Kind of following that example though. So so say you take a look at it. You tag it once is clean Is there any feedback to us as importers so that we don't have to continue filing that registry information Over and over again, and I think we're kind of starting to move into maybe what could develop as a trusted trader program Or something along those lines But but at some point there has to be some efficiencies to for the importer For you know importing only compliant product that meets other requirements has all their appropriate documentation that sort of thing So we're not in this situation where we're just filing hundreds of thousands of vans every year that You know aren't really problematic I'm in general agreement. The the basic idea is that as product is reviewed And we've done it once we don't need to do it again And this is this is a staff opinion That we've got a recordation on that if we see that in a repeated fashion over and over You know we pretty much can say the products are generally clean if there's issues you review it domestically Yeah, so I'm in total agreement Yeah, we're we're going to need to move in that general direction longer term. Yeah, it's a resource issue as well I definitely see the where you're going with it. I think it's it's we'd have to We'd have to think through how How that works, you know, how how that works where we know And we're comfortable that that product you wouldn't need to file any any longer I do think it around a trusted trader program is probably Absolutely benefits around that I mean, I I do think you know going along like the the scope of the of the alpha pilot was was very broad And and we we set it up that way because we were trying to Define volunteers to participate. I think moving forward. It really makes a lot of sense for cpsc to To make some decisions on what what data for what products we really need, right? We have a we have a vast jurisdiction And but you know quite frankly, we don't have the resources to to target and examine everything under our jurisdiction. So Where do you make those cuts? You know where what data is Is really important to us to to enhance our import targeting So that's a that's another area around scope moving forward that we need to we need to look at Right of the 8800 that we have jurisdiction over roughly 8800 touching 63 some chapters We really only are interested in in terms of standards somewhere in the realm of 300 to 500 codes where we would be looking for children's products things for which there are there are potential issues It's not going to extend much further than that. We believe We just need to get the intelligence to be able to understand because as you know, some of these hts codes are kind of rough to peel back And and to know what's in there And so as we work with itc to to clean up the hts codes to make it easier for us and easier for you to work with us Because that's not what the hts codes are originally designed for there for tariff collection Um, as we are able to stream that down and be more consistent I think it's going to be easier for everybody to understand how reliably we can set this up in terms of need for the information Um, so it it takes time for on our side as well I did want to address were you going to tell me it's time to move on? Okay Did you have another go ahead, please I actually wanted to go back to something magna said Talking about the way you store data at Ikea because early on we had some email exchanges And a bullet point number I guess four on here about voluntarily filing the full certificate data We've had some people indicate that the way you store data is Based on the way cpsc has historically requested that which is Provide us with a certificate And so we are interested In some more information around that Because I think it had been expressed by some people that would have been easier in the beginning Just to provide everything you had which was certificate data Um, can we kind of get some feedback around that like would it have been easier? Would would there be an interest in being able to voluntarily file The full certificate not not only like we're not taking away the I don't think the option of of what we've had in the registry But for some people whether they've been easier to just provide the whole certificate data because that's how you store it Magnus, I'll let I'll let you address a little bit because you did all the manual entry They manually entered everything into the registry Um, and I believe we did about 50 different articles for which we did that We're similar to walmart as you can if you can imagine the range In that we're going to have a wide breadth of articles We only tested with a limited amount and when we entered the certificates in the registry It was only for 50 different articles of various sizes of mattresses that were coming only from Mexico and going only through Laredo, so it was very very narrow Um, but we specifically knew that that's where we wanted to test that particular concept Um, there were some other issues. So you have the structured and the non-structured on the entity listing For us. It's just it's a gcoc. So it's it's a field that has the full unstructured address Um, imagine having to go back and now unstructure that data for a structured feed If that's the way ace and cpsc is um looking forward to moving So that becomes problematic for us versus just being able to put the certificate on file Or being able to mimic the certificate in a data feed And I think um one of the other things that we did test was an edi feed into cpsc for the certificate information That was very difficult for us to set up just for the pilot But long term for volume purposes It would become resource issues if we had to manually enter every gcoc And then think about it from a maintenance standpoint. So if your gcoc changes for that particular product Now you have a maintenance conversation as well that piece wasn't tested. So nobody manually entered that into the register Did you want to I can come I can comment on this and basically We have the whole subsequent compliance as bits and pieces of data Which means that it's no big deal to assemble it in different ways And some of these adaptations were done during the pilot For the pilot to be able to run it more efficiently. There's those more parts to do but basically if we full pilot full certificate data or if we file Before these four elements, uh, that wouldn't change the most administration for us But it will change the amount of data that goes through the feed into cbp and in trace Plastic if we can reduce it. So uh, the issue we had also must say that we were running both weapons pga set and full full pga set for this pilot and what we My experience with the product register is that it was fairly easy to use And it was quick if you work with the simple products like the mattress But the toys are messy Because you have an enormous amount of different codes to choose between that is relevant for a toy So that is substantially more heavy to work if you're going to do it manually I will say four to five times worse than a mattress When you say when you say codes are you talking about product codes organizing those product codes through because I know the hts codes It's very simple. Yeah, and now I'm talking about this citations There's substantially more citations available for toy than it's for mattress You have a great basically two general versions and two children versions for mattress But for a toy you have 46 to 47 different A breakable citations Which makes the toy much more messy to register manually As Lori said, we didn't quite feed To go back with the feeding the progress records the records to another data upload Is that Every time you send something out they want something back You add a point where the data flow could break down And that is the bigger worry technically if I don't see it's a big issue to solve either I can mention that we we have about Three and a half thousand products where we have a certificate of compliance for and we Have an average Due to the high amount of the component testing About Two and a half to three updates per year. So somewhere around 10,000 different certificate compliance during a year And then naturally multiplying that with the number of entries. I don't know where we end up, but There will be a lot of data that will be fed A lot And from wal-mart's perspective, it was it was a manual entry So any additional fields that we that we would have to submit would just be more key strokes and more time and effort So I believe we're at the point where we need to move on to our our next topic And we want to talk about the product registry So, you know, again, we got we've already sort of the Discussion of the registry has already been sort of intermixed into What we've been talking about so far And I think I guess just to sort of kick it off and you know, I think everyone manually entered their products into the registry and I mean we fully acknowledge that Moving forward there has to be some sort of Easy efficient way of uploading products into the registry for this to be For this to be viable for for companies, but you know sort of with that You know would just open it up to any other discussion as far as, you know Thoughts on the registry and sort of what worked and what didn't You know suggestions for the future Yes, jim this is lori and magnus can can jump in as well But when you say upload when I think of an upload from a business perspective I think of somebody sitting down at a computer and uploading the data manually And I think if you're talking volume that becomes Very unworkable Every time you get a change So as Magnus has said we could have upwards of 10,000 different certificates being uploaded annually Somebody has to upload that the preference would be is there some form of edi feed for the certificate so that Anytime a source system is changed That you can create business rules or triggers that would automatically trigger the feed into the cpsc registry And then you would have some form of confirmation coming back that it was It was received in the the number or the register number is the same I think for a larger larger customer this john cpsc for larger Businesses it makes a lot of sense to establish that type of an edi if we were going to move forward To definitely have that type of Recognition that or there's an expectation that you've got a large array of products for which there may have been a change in your In a component in a particular supplier And therefore you needed to alter your Your certificate for one reason or another. I'm not a lawyer. I might not be getting all this right But For the moderate and the smaller Importer this what you've done really is is kind of their test For somebody that's going to be getting into the system to actually File necessarily and they're they're they're moderate. They're small. This is what they have to experience So this really is to me This is still a real-life test in terms of the interaction And I understand being very large wanted to get you in the room to to make sure that we understood where you're coming from when we Fully addressed your concerns as well but The amount of data and how you did it is is what every day Smaller importers are going to have to deal with so I can't tell you like see that the trial I uploaded most of these certificate myself personally. You also see how the system works and the logic of it and It it worked it was a good layout good logic and I didn't Have any problems with the behavior also on For if you know if you know what you're doing it took me about Uh somewhere close to three three and a half minutes For the second certificate I uploaded the first one took a little bit more time because you need to define the supplier But then you there are the producer of the mattress But then you could reuse the information So I would guess that less than five minutes work if you have a normal certificate of compliance I would guess that for toy Certificate you probably have to spend Two to three times the time to do that And unfortunately when I see small importers of toys they can equate a lot of different products. This was not just Not big volumes of each One problem my experience was that when you do a download of the data from the register It doesn't include all the identify Identification fields that you have filled in information And that was an issue because one of them contained the data we need would have need to automatically link up their certificate number with The rest of the data Magnus, this is lisa. We did we did hear that not only from you, but from some of the other participants that The export the download of what you had entered was great But it didn't have all the fields you needed and we do actually have that on an enhancement list for going forward with the beta You know a second point. I think john kind of made which is that the alpha pilot was pretty small and we we did create a web service that was for the Direct integration between one of your systems and and the registry But I think well a no one used it And I think the reason was is no one was planning to do thousands of products in the alpha And so it became this, you know, is it easier to Just enter these 100 200 products whatever it is into the registry or to set up a whole web services And obviously everyone chose manual I think that that choice will change as we move forward into the beta or into A bigger a bigger full, you know full production system and and maybe web services isn't the right answer to You know, we we were trying to create something from based on the feedback we heard But I think we all do acknowledge that some sort of technical integration with the participants or with Industry in general who you know with employers in general who are working this with absolutely be necessary We you know, we wouldn't expect that people are going to be manually entering things Large companies, but john also makes the point that you know What this helped with is there are going to be some small importers who their whole experience is going to be what you experience in the alpha That's just all the products they have and so kind of understanding how the registry helped and how the the Reference pga versus the pool full pga can help some of our smaller importers going forward You know is also kind of the outcome in the feedback from from this alpha pilot So this is ken from walmart just a couple thoughts one on the on the web services piece And I think this is going to be a challenge for all of us too as we look to see how we want to scope out the beta Is it there's also a hesitancy and i'm speaking from walmart's perspective to invest too much In in systems and development and enhancements and things like that to tie into web services or to tie into whatever the beta might look like Knowing that it's a test And that whatever the final outcome Might end up being could be totally different than the the test system that we just invested funds to build around so you know from our standpoint it was it was You know, we were being a little more cost conscious as much as anything to manually enter it before we go out and Engage our it folks which usually has a lot of zeros after after the projects that come with that so So I think that's another thought around that is as we start to look forward the bait towards the beta We ought to Be careful about that as well. I think The other piece around the private registry and cara on the line from our team may have some other comments about this But I think our experience was it was a good tool, you know, just From the perspective of a small importer You know who won't be doing a lot of this. I think we found it to be user friendly intuitive Really kind of meeting the needs of what someone in that situation Might might need, you know, that that that type of interaction in care. I don't know if you have any other thoughts But but generally our our our experience was good with it I wanted to also ask I know sort of early on in our discussions about about the pilot There was conversation around The possibility of having Other entities enter information in the registry on behalf of the importer I don't think that ever played out like a like a third-party testing lab or some other Some other entity that would that would compile data Any thoughts on You know, if we were to move forward in a beta You know the opportunity for that to come to come about Actually, we we approached a couple of testing labs with regards to electronically sending the data Into our companies so we can manipulate it Keep the data electronically and send it back out and I don't think they were very They didn't have a lot of the technology set up to do that I think they're waiting for Some more direction on which way the pilot and which way this is going to move forward before they invest Any resources into that But as this grows and it becomes tens of thousands of Venturies a year for a medium-sized importer if you're testing three and four Different items on a single product. I could see where Anyone could see that this is going to grow in cost and scope and volume to where you're going to need To integrate it electronically. I mean, there's no way other way to move the information Nobody's going to be king that information It's it's got to move forward electronically Okay, hi, this is Cara. Can you hear me? Yes Okay, sorry. I was trying to speak a little while ago and for some reason nobody could hear me Um, just going back to kin what kin had mentioned the system was um, was easy to use It was very user friendly. So for smaller importers. I don't think that there would be an issue It was fine consuming just based on volume But the system itself was not difficult Key thing is that Procter and Gamble and and I just want to weigh in an agreement with Cara and kin on we used the registry as well and kind of represented Of small to medium in the pilot. We didn't have many items that were participating But we found the registry easy to use we do also share wal-mart's concern of thinking a lot of money into a automated That we're not confident would be the one going forward for full implementation Um, this is Cara Haas from fruit of the loom and I just wanted to weigh in on a few points as well We loaded around 800 products manually to the registry um, and although the actual functions were pretty user friendly we did find it difficult to edit products if Something was entered incorrectly As well as editing the um saved manufacturers addresses um So we had to actually delete products to reload them which added time to the process um also We noticed that when entering the product manually and saving them that Once that save function you receive your reference number It would bring you back all the way to the main page Which then you would have to choose to enter a new product again And I think that um for companies that are manually entering the data Allowing you to remain on that enter page Would help with some of the time consuming elements of it um And also one of the things that we were envisioning in terms of an upload would be potentially like an excel or a csv spreadsheet upload As that's how we maintain a lot of our data We export from our Oracle system and Pull the data from some other resources And that's how we currently send to our broker in a lot of instances. So having that function would be helpful as well We also had issues as far as editing in the registry I had to delete some of our Items that were put in as a duplicate and it took it didn't Repurpose the number so it looked like Uh, we deleted those numbers for some reason other than it was just a duplicate um We also had trouble um with other editing issues But I do agree with the the last Speaker That it can be done But we need to have it in excel as well Um, this is Cara from Fertilum again. I just wanted to add also that um After the pilots had been completed we came to realize because the The um Scopes of what we were filing was so small and we picked very specific manufacturers to correlate to specific products that The registry would actually become almost impossible for us to use because The same product can be manufactured at multiple facilities and the product ID or few number doesn't change So we would end up having to load the same skew number Multiple times to generate additional reference numbers to accommodate the additional manufacturer locations I wanted to um agree with a lot of the statements that were made but also emphasize that we had um some pretty substantial issues with trying to edit entries and also Um thought that it would be interesting to see if we could create a separate list of manufacturers names You know an entity list perhaps rather than having to re key that by part number And and also the list of citations or regulations to have that in a different format So it was easier to to reference the ones that we were looking for And this is Keith from fnt. Um, just to go back to bob's point about your question jim with third party laboratories I agree with bob most of the labs we spoke to we work with bv. We work at ctl Both walmart laboratories. They have taken a wait and see Kind of approach to it the other problem that when we spoke to them is Even if you looked at a bv and a ctl report for a walmart product They'll look completely different from each other In fact, sometimes even some of the test methods could be different for the same product that you're testing Until we have some kind of standardization as to what the formatting should be and maybe even the test methods I don't know that we're going to be able to do it as easily As as we would like to um to go back to what ken said Depending on what information you're looking for it could take you several minutes It's just to find the information that you need to put into the certificate and then finally upload it And we we make a relatively small amount of products. We're basically in the children's apparel business Somebody like ike here and walmart. I can't imagine with the thousands of products that they make How how much more expansion they would be on that? thanks So it sounds like um a number of companies talked about issues with editing and then the last comment about I'm sort of having I guess separate lists of manufacturers and regulations I guess that would be sort of that uh that hot list that that you would keep going back to those are um really good Really good feedback for us Hi, sorry, just one thing if you're on the phone We are getting a lot of kind of background noise here if you're not speaking if you wouldn't mind just muting your phone Thank you um so question there were a couple comments about um You know going in and and I guess the attempt of of editing or changing the information What what um what prompts what what would need that is that a is it was that a um an error Just a data entry error that you had to go back and fix or was there something about um The information a change in the manufacturer or or something else that that um Prompted the need to go in and edit the record Can we just get a little more uh background on that? Here from fruit of the loom I mean some of the reasons why we had to go in and edit a record was simple since the demand you will upload typos in an address or in current country was indicated in an address um You know things that may potentially be a limit if we're working on uploads Um, but having someone sitting there, you know for eight to ten hours the data to load the product There were just simple clerical errors Great. Thank you Jim, I think that may come back. Well, we didn't test this um because we only did the one supplier But when you have to modify or change something say you use a different laboratory for a new test when you retest for your annual testing That would result in and having to change your gcoc If you add a new regulation, I hope you don't but If you add any new testing or regulations that again results in a modification Um, so every time you do change management Somebody's either have to has to go in manually to change it or in the case of of your large importers Are going to have to have some form of a trigger to be able to modify that data in the system Uh, we should know if you retest the way It was set up in the alpha as long as it was tested by the same Test lab Because we didn't include dates of testing. You shouldn't have had to change that correct Correct But going forward in a real live scenario where you have multiple laboratories that you're using for testing purposes It is feasible that you could change your laboratory Over time and if we're talking, you know long term type of application I think that's something that you have to think about holistically well, yeah So just sort of um on complexity So we're always looking at sort of data that's available in a lot of different ways It's like what data is out there? What data what data could we potentially use? So, you know, there are Various dates associated with products with with certificates data manufacturer data testing Would anybody like to offer any any thoughts on sort of how How dates would factor into this as far as complexity of Maintaining records in the registry or filing data in in general How how often do those dates change and how much of a of a burden is that? Could you could anyone shed some light on that for us? I Can Give some input on that today we Have an average of we are doing a lot of the testing on component level And because of that you also get a lot of records in the certificate of compliance due to different test labs and so on and We basically we issue a certificate of compliance an average of about three times two to three times a year and That in itself is not the Issues is we need to come Keep the certificate of compliance Up to date all the time. So that's that's we have to do anyway but The log is I looked at For if we can produce the product registry was to force a new record in the product register every time we do an update of the certificate of compliance to have a matching which means that there were our Human we did both certificate of compliance That's who could hand out to the customer and so on Would match exactly with the information that is in the product registry always In in relation to dates as well We have to think about when that product was tested how often that product could potentially be tested And when that product is going to enter So, you know, we have replenishment items that come in You know multiple times throughout the year And if that particular product is going to be tested multiple times a year, we would have to essentially Align our replenishment item with that testing, you know and even new products as well so The time of the test versus the actual entry of the product into the registry Well, it would have to be done prior to entry in order to make that Registry product registry valid to the item that's being entered or else it'll be negated Or rejected. Yeah, and that was you know, it was um The commission decision on going with the with the four elements from the certificate in the check box, you know specifically excluded dates which really From a data entry perspective in the registry really streamline things because if you enter a product One time and The manufacturer doesn't change the regulations don't change really that product is good In the registry and as valid that reference number is valid for For as long as you would import that so that that really did streamline I think a lot of the the data entry, you know, although again, you know a lot All of you did that did this manually, but but it didn't require updates as far as dates go But we just we really just wanted to have a little discussion around that and understand the the complexity that dates add to to the process Yes, I think jim to echo what walmart has said Is that dates become problematic over time? Um, and we will have to consider Um How your inventory methods and your distribution network function in order to really accommodate the dating especially from a replenishment standpoint The other aspect to that too from a date perspective is product changes so colors can change which can Cause trigger another test on a toy depending on the color So That you know Our merchants make those changes all the time without necessarily consulting us first. We just have to act on it So that can add a level of complexity to the date as well the date issue as well So I think we're ready to move on to our to our next topic But this is probably a good place to just take a 15 minute break let everybody stretch their legs a little bit So I think we will pause here and for everyone That's viewing the webcast on the phone. We will reconvene at 10 35 And we'll start back up with talking about broker interaction. So Thank you