Request for Information: Consumer Product Recall Fraud

The National Association of Manufacturers (NAM) supports the CPSC's efforts to address consumer product recall fraud, noting that fraud causes significant financial, operational, and reputational harm to manufacturers. They recommend that the CPSC implement advanced image verification technologies, require complete products for returns, establish guidelines to close recalls after a set period, and create an industry working group to combat fraud.

GS1 US, a non-profit organization that manages global product identification standards, supports the Commission's efforts to mitigate recall fraud. They argue that adopting standardized identification (like GTINs and serialization) and digital links can improve recall accuracy, provide better traceability, and help distinguish legitimate claims from fraudulent ones.

The Toy Association, representing over 900 toy industry members, supports the CPSC's initiative to address consumer product recall fraud. They argue that the rise of AI-generated fake photos has undermined the reliability of photographic proof for recalls and recommend that the CPSC require the physical return of products or critical components to manufacturers to ensure the integrity of the recall process.

The Procter & Gamble Company supports the CPSC's focus on consumer product recall fraud, citing their own experience with significant fraudulent activity during a Tide & Gain recall. They argue that prolonged Corrective Action Plan (CAP) periods create opportunities for fraud without providing additional consumer safety benefits and urge the Commission to work with firms to facilitate timely closure of CAPs once outreach has reached maturity.

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.

Perry Somers, founder of ReceiptHouse, suggests that the Commission should establish a consumer-controlled standard for purchase and ownership records to combat recall fraud. He argues that by creating a verified record of ownership before a recall occurs, the Commission can distinguish legitimate claims from fabricated ones, similar to the "Blue Button" initiative for health records.

Recall Results, a recall administrator, supports the Commission's goal of strengthening tools to detect and deter fraud in consumer recalls. They argue that the rise of AI and "professional recall customers" necessitates advanced fraud detection technologies, such as live photo capture and specialized registration websites, to prevent the overstatement of recall effectiveness and the unnecessary cost of fraudulent remedies.

Sedgwick, a company providing logistical support and recall execution, highlights the significant operational and financial burdens caused by sophisticated recall fraud. They advocate for the Commission to issue guidance on fraud risks and establish an Industry Advisory Committee to facilitate information sharing and best practices.

Intertek Testing Services NA, Inc., a testing and certification organization, supports the Commission's efforts to address recall fraud by highlighting the need for better product-level traceability. They argue that the Commission should focus on requiring importers to surface shipment or lot identifiers on the products themselves to help distinguish between genuine and fraudulent recall claims.

The Baby Safety Alliance, a trade association representing manufacturers and suppliers in the juvenile products industry, supports the Commission's efforts to address consumer product recall fraud. They recommend that the Commission recognize product returns as a primary anti-fraud measure, account for the risks posed by generative AI in creating fake evidence, and allow manufacturers flexibility in choosing verification methods based on product risk.