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.

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 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.

Truepic, a technology company, supports the Commission's efforts to address recall fraud and advocates for the adoption of image authenticity and provenance verification as a best practice. They argue that their "Vision" platform can effectively detect organized fraud networks and AI-generated deception while maintaining a low-friction experience for legitimate consumers.

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.