Comment from Household & Commercial Products Association (HCPA)

Summary: The Household & Commercial Products Association (HCPA) supports the Commission's efforts to address recall fraud while advocating for a balanced, data-driven approach that avoids overly prescriptive requirements. They argue that the Commission should prioritize measurable safety outcomes, such as retail inventory recovery, and establish clear criteria for closing Corrective Action Plans (CAPs) when they are no longer providing meaningful safety benefits.