Product Safety & Compliance Information

Printable Overview Documents

Click here for California Prop 65 Q and A for 2018 Clear and Reasonable Warning Regulation Overview

Click here for ADG Promotional Products Product Safety and Compliance Overview

Click here for Article: Taking The Long View Of Compliance Programs

Corporate Safety & Conduct Policy

ADG Promotional Products are tested by independent laboratories to ensure all materials are safe and meet or exceed industry and government established standards. At ADG, we do not stop at the minimum level but strive to ensure that we consistently exceed all mandated standards in the marketplace.

ADG Promotional Products complies with all laws and regulations applicable to its operations and premises in the United States & Canada including, but not limited to, those enforced by the U.S. Consumer Product Safety Commission (CPSC) and Food and Drug Administration (FDA), as well as the California Safe Drinking Water and Toxic Enforcement Act of 1985 (Proposition 65). All ADG products are safe for their intended general usage as a promotional item.

ADG is committed to operating in an ethical and responsible manner. We have adopted a Commitment to Ethical and Responsible Conduct which is recognized by the promotional products industry and covers, among other things, product safety, workplace standards and community focus that exist throughout our global sourcing efforts, production facilities and operating processes.

Commitment to Safe Products

ADG acknowledges the need for established compliance standards, requirements, rules, and regulations. We produce compliant products, to promote safety, and implements testing procedures to verify compliance, and auditing when necessary and appropriate.

Compliance with all applicable laws and regulations in the United States & Canada, including but not limited to those enforced by CPSC and FDA, as well as Prop 65;

• Using CPSC accredited third-party laboratories for all required testing.
• Affixing tracking labels to products or providing complete batch and lot iinformation.
• Conducting annual undue influence training for all personnel selecting or working with third-party testing laboratories.

Conduct all necessary testing and certification, for general use products or children’s products that will:

• Obtain test results in English and in a manner that allows for identification of the product tested by lot and batch, the test(s) conducted, the date of test(s) and testing lab.
• Provide copies of all test results to Distributors as requested.

Provide timely information about incidents, safety issues, and non‐compliances for products supplied by ADG.

Share any inquiries from or affirmative contact with government agencies about any products supplied by ADG.

Fully cooperate with Distributor’s efforts to audit compliance as required by their Clients.

Commitment to Distributor Partners and their Clients

ADG believes strongly in providing the safest and highest quality products by focusing on the following:

• Social Responsibility and Environmental Stewardship
• Supply-Chain Security and Discipline
• Product Quality, Safety and Compliance with Federal and State Regulations
• On-going Testing via Independent Third-Party Laboratories

ADG has an operating philosophy to exceed expectations of Distributors and their Clients each and every day. ADG has established standards for the integrity of our products and processes that demonstrate we are committed to respecting the rights of Individuals while protecting our communities and environment.

ADG is also dedicated to “Helping Distributor Create Positive Client Experiences” by complying with the applicable laws of each community we operate in and to conduct business in an ethical and responsible manner.

Commitment to Ethical and Responsible Conduct

ADG Promotional Products believes we are guided by the highest ethical expectations of our Distributors and their Clients. We have adopted standards for the quality and safety of the products we sell, and we are committed to assuring that our manufacturing processes respect the rights of individuals, while also protecting the environment of the communities we operate in.

ADG will comply with all applicable laws, and we will conduct business in an ethical, responsible manner.

We expect the same commitment from everyone that provide ADG products as primary manufacturers or component subcontractors. We also expect our suppliers to maintain procedures to ensure continual compliance and open their factories & records for audits by ADG’s staff or qualified third-party organizations.

(Product Safety)

• Compliance with Laws and Standards. We will comply with all applicable laws and regulations regarding safety of products we sell. Where feasible and appropriate, we will meet or exceed applicable voluntary industry standards for our products and processes.

(Product Quality)

• Expectations Consistently Met. We will support and expect manufacturing processes that ensure consistently met expectations of agreed-upon product quality and functionality.

(Social Compliance)

• No Abuse of Labor. We will not use any form of forced labor, including indentured, prison, bonded, or slave labor. Physical abuse, the threat of physical abuse, sexual orother forms of intimidation shall be prohibited.

• No Child Labor. We will comply with all minimum age provisions of applicable laws and regulations.

• No Discrimination. We will not discriminate in employment hiring practices on the basis of age, nationality, race, religion, social status, ethnic origin, gender, sexual orientation, disability, or other protected class.

• Hours and Wages. We will comply with all applicable wage, work hours, hiring, benefits, and ovetime laws and regulations. In the absence of law in a particular location relating to product safety, labor, employment, environmental or working conditions, the spirit and intent of these policies will guide our business decisions.

• Workplace Conditions. We will provide a safe, healthy, and secure workplace. We will abide by all applicable laws and regulations for safety and health.

(Environmental Sustainability)

• Minimize Adverse Impact. We will abide by all applicable environmental laws and regulations. We aim to manage production processes, energy/water usage and waste systems for maximum efficiency and minimal adverse impact on the environment.

(Supply Chain Security)

• Product Security through Delivery. We and our supply chain partners will implement procedures that ensure products have not been changed or tampered with from shipping point through delivery.

• Ethical Behavior. We and our supply chain partners are expected to conduct their business in accordance with the highest ethical standards and will strictly comply with all laws and regulations on bribery, corruption and prohibited business practices. No money, assets, gifts, fees, bribes or compensation of any kind may be given to our Employees or our affiliates’ Employees in an attempt to unduly influence such person’s decision making abilities

ADG Promotional Product’s adoption of this Commitment to Ethical and Responsible Conduct Code expresses our sincere commitment to the business principles stated and to the promotional products industry in total. It is our guide to conducting our business decisions and relationships. However, by adoption and application of these business philosophies, we do not waive and expressly reserve all our rights granted us under applicable law.

General Questions

What is a General Certificate of Conformity (GCC)?

GCCs are based on testing or a reasonable test program and include the identification of the product covered by the certificate, citations of each regulation or rule the product complies with, identification of the manufacturer or importer of record, contact information of the individual maintaining corresponding records, date and place where the product was manufactured and tested, and the identification of the testing lab.

Do all products require a General Certificate of Conformity (GCC)?

No. Items deemed as general use items are not regulated by and therefore do not require a General Certificate of Conformity. If a GCC is required it will only be issued on products manufactured as of November 12, 2008. Products that are not regulated by a federal regulation or rule do not require a GCC; however, some manufacturers and importers will issue a GCC for such products. ADG issues GCCs for regulated items, and will, upon request and on a case by case basis, issue a GCC for an unregulated product.

Is ADG required to supply GCC’s to Distributors?

CPSC rule states if a GCC is required on the product then ADG is to provide reasonable means to Distributors to access these certificates.

For any products regularly shipping from any ADG facilities, all required GCCs will be kept on file and available via request to ADG’s Customer Service Team (800.852.5208) or service@adgpromo.com

For direct overseas special orders, all required GCCs will be kept on file at ADG and can be provided to a Distributor upon request.

What is Undue Influence Training and does ADG do this type of training?

Undue Influence Training is training to make sure that manufacturers and their Employees do not exert undue influence on testing labs to alter test methods or test results that serve as the basis for certifying a product’s compliance under federal law. All ADG Employees involved with sourcing or testing product are required to undergo undue influence training on an annual basis. ADG is committed to ensuring that no Employee exercise undue influence on any testing lab. No Employee is permitted to take any action that could undermine the integrity of test data, and we instruct our Employees to promptly report any incident of undue influence they may witness to ADG’s compliance specialist as well as the CPSC directly.

What is the definition of a Children’s Product?

A “children’s product” means a consumer item designed or intended primarily for children 12 years of age or younger in the United States and children 14 or younger in Canada. In determining whether a consumer product is primarily intended for a child, the following factors will be considered:

• A statement by the manufacturer about the intended use of the product, including a label on the product if such statement is reasonable.

• Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children.

• Whether the product is commonly recognized by consumers as being intended for use by a child.

• Logo and/or imprint are utilized on a product to specifically target children.

What Is A Tracking Label And When Are They Required To Be Used?

Under CPSIA guidelines, Children’s Products must have distinguishing permanent labels that are affixed to the product and its packaging and provide certain identifying information that is visible and legible. Tracking labels must contain the following information:

1. Manufacturer or private labeler name;
2. Location and date of production of the Children’s Product;
3. Detailed information on the manufacturing process, such as a batch or run number, or other identifying characteristics; and
4. Any other information to facilitate the specific source of the product.

ADG has adopted the Promotional Products Association International (“PPAI”) protocol for assisting Distributors and their Clients in locating the required tracking label information in a specially created website which is referenced on each tracking label.

Mandatory Third-Party Testing and Certification of Children’s Products

Under CPSIA, Children’s Products are required to be tested by an accredited third-party lab, and the manufacturer or importer of record is required to certify that the Children’s Product complies with applicable law based on such third-party testing. ADG has established a Children’s Product testing program that is in compliance with CPSIA and will issue a Children’s Product Certificate (“CPC”) in accordance with applicable law.

What is the Flammable Fabrics Act and are ADG’s products required to comply with it?

The Flammable Fabrics Act is a federal regulation governed by the CPSC that regulates the manufacture of highly flammable clothing. Products subject to the Flammable Fabrics Act which are manufactured and sold by ADG are in compliance with the Act and ADG will issue a GCC certifying such compliance.

General Compliance Statement of Lead and/or Cadmium Content in Inks Used

ADG is committed to providing high quality, safe products for sale in the marketplace. We have worked with our supply chain partners to implement a process to help ensure that product and decorating raw materials meet federal and state health and safety standards, including California Prop 65.

ADG purchases inks from well-established, reputable domestic suppliers in the United States. We have worked closely with our ink suppliers to test and document lead content for all ink systems used to decorate ADG products. The lead content of all inks used in production meet current CPSIA regulations.

Inks used in all decorating processes are tested by a qualified third-party testing laboratory from:

• High Definition Imprint (HDI)—“Full Color Digital”

• Pad Print

• Silk Screen

• Hot Stamp

• Toners

Since ADG Promotional Products offers thousands of items on a made-to-order basis each individual product cannot be feasibly tested independently. ADG makes this General Compliance Statement in good faith based on independent third-party laboratory testing results of undecorated products and the various materials used to create specific advertising messages and the unique imprints on each item. Additionally ADG has established and maintains test protocols that complete periodic testing to confirm compliance with federal health and safety standards including Prop 65.

How often do you audit manufacturing facilities and what standards are set?

ADG Sourcing and Product Development teams visit our overseas production partners multiple times each year. All completed goods go through a “QA Inspection” (quality assurance) prior to export shipping to North America. Our production facilities also undergo periodic third-party audits as well.

Can you remove the “China” markings from items?

Federal regulations (19 U.S.C. 1304) require this information remain on each product (country of origin). It designates the country of origin the product comes from.

Can you provide NAFTA Certificate of Origin documents?

Products manufactured in Asia do not qualify for NAFTA. We can provide certificates for those items produced and originating in North America.

Are you always aware of what country the product was manufactured in and by whom?

Yes, most ADG products are manufactured in China or the US but there are some products from a few other countries. We document that information on the GCC.

What is California Proposition 65 (Prop 65)

California’s Safe Drinking Water and Toxic Enforcement Act of 1986, also known as Prop 65, requires a warning notice on products that contain chemicals identified by the State of California to cause cancer or reproductive toxicity.

Over 900 chemicals are on California’s list of Prop 65 chemicals and can be found at www.oehha.org/prop65.

ADG decorates products using materials compliant with current US Food and Drug Administration (FDA) guidelines. The state of California decided to expand on Federal standards by enacting legislation that does not ban products but simply requires compliance with the law by using individual product warning labels "Right to Know Law". All ADG products in their undecorated raw material state comply with Prop 65 guidelines.

To insure meeting Prop 65 guidelines ADG labels products free of charge that may ship into the State of California. The label will read as follows per direction from the State of California and the Office of Environmental Health Hazard Assessment:

WARNING: Cancer and Reproductive Harm www.P65Warnings.ca.gov
The warning must be on the product and any advertising material offering the product for sale. Failure to provide a warning when required can result in financial penalties. If you have a specific compliance need, please feel free to contact ADG Customer Service Team at: 800.852.5208 or service@adgpromo.com

What industry standards apply to ADG’s products?

The promotional products industry has no specific or established industry wide standards other than those set by government regulations and from commissions like CPSC. ADG has established processes and protocols in place to ensure compliance with applicable standards and continues to look for better methods to bring high quality, safe and reliable products to the marketplace.

The industry’s non-profit lead association (PPAI) provides more information and overview on product safety at: www.ppai.org/productsafety

If you have questions about specific standards, please contact the ADG Customer Service Team at (800) 852-5208 or at service@adgpromo.com

What third-party testing laboratories do you use to evaluate products?

ADG in conjunction with our parent company (Taylor Corporation) uses globally recognized laboratories to provide independent analysis and feedback on all of our product categories.

• AI/Asia Inspection

• Anseco

• Bureau Veritas

• SGS

• Intertek

Consumer Products Safety Improvement Act (CPSIA)

What is the consumer products safety law?

CPSIA was signed into law August 14, 2008 as Public Law 110-314. This federal law expanded current CPSC (Consumer Products Safety Commission) authority www.cpsc.gov and created responsibilities for those who make, distribute and sell consumer products including items intended for children’s usage.

ADG products meet current CPSIA standards and guidelines so that Distributors and their Clients can be confident they are receiving the safest products available in the marketplace. ADG’s product offerings are primarily designed for general use by Adults and are not intended for children age 12 or younger unless specifically stated in product descriptions. However, a Distributor and/or their Client, by ordering a specific advertising imprint, may render a product as targeting children by doing the following:

• Utilizing marketing content and/or advertising images specifically targeting children
• Normal consumer recognition of a product changes, as it was originally intended, to reach the children’s marketplace because of its imprint

ADG is not liable, nor expressly does not indemnify, Distributors and their Clients when their decisions make general usage products after being decorated with intent of primarily reaching the market of children.

What is the Consumer Product Safety Commission and what does it do?

The Consumer Product Safety Commission (“CPSC”) was established by Congress in 1972 and is an independent federal regulatory agency charged with reducing unreasonable risks of injury and death associated with consumer products. The CPSC achieves that goal through education, safety standards activities, regulation, and enforcement of the statutes and implementing regulations. The CPSC has jurisdiction over thousands of types of consumer products used in the home, in schools, in recreation, or otherwise. To carry out its mission, CPSC administers seven statutes passed by Congress. They are:

1. Consumer Product Safety Act (“CPSA”), 15 U.S.C. 2051-2089;
2. Federal Hazardous Substances Act (“FHSA”), 15 U.S.C. 1261-1278;
3. Flammable Fabrics Act (“FFA”), 15 U.S. C. 1191-1204;
4. Poison Prevention Packaging Act (“PPPA”), 15 U.S.C. 1471-1477;
5. Refrigerator Safety Act (“RSA”), 15 U.S.C. 1211-1214;
6. Virginia Graeme Baker Pool and Spa Safety Act (“VGBA”), 15 U.S.C. 8001-8008; and
7. Children’s Gasoline Burn Prevention Act (“CGBPA”), 110 P.L. 278.

Canadian Consumer Product Safety Act (CCPSA)

All ADG products meet the requirements of the Canadian Consumer Product Safety Act (CCPSA). New lead and phthalates limits have been incorporated into this law, which came into effect June 20, 2011.

CCPSA is a Canadian consumer product safety law and applies to a wide variety of consumer products manufactured and sold in Canada including children’s toys, household products and sporting goods, but excludes products like motor vehicles and their integral parts, food, drugs, and animals, each of which are regulated by other Canadian laws.

The law requires that all consumer products that have contact with the mouth meet lead limits of 90 ppm or less in substrates. In addition, toys must also meet the lead and mercury limits of 90 ppm or less in surface coatings. Phthalates requirements are applicable to childcare articles and toys, with the limit of less than 1000 ppm for each of the banned phthalates (these include: DEHP, DBP, BBP, DINP, DIDP,DNOP).

The definition of “toy” and “childcare article” differ slightly from that of the US Consumer Product Safety Improvement Act (CPSIA). Under CCPSA, a “toy” is defined as a product that is intended for use by a child under 14 years of age in learning or play. A “childcare article” is defined as a product that is intended to facilitate the relaxation, sleep, hygiene, feeding, sucking or teething of a child under the age of 4.

ADG will continue to monitor changes in the CCPSA law in order to ensure compliance with applications and regulations.