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Compliance and safety statement from Nolwenn LLC.pdf
Product Safety Policy Statement
Nolwenn LLC is dedicated to providing its customers with safe products that exceed their expectations for quality and safety, designed to comply with all statutory and voluntary standards and regulations.
We have policy of an executive level for Product Safety and Compliance from Purchasing, Production, Operations, and Marketing that report directly to company Ownership and together have developed robust policies to deter, detect, and prevent non-compliant product from shipping to a customer.
The foundation of these policies is based upon open daily communication internally and with our sourcing partners throughout the supply chain. Procedures have been established for product design and performance as well as raw material certification, regulatory requirements, traceability and the validation of communication leading up to the Design Approval Process.
Additional procedures are in place for internal and external Third Party testing and Corrective Actions ending with manufacturer based and domestic inspections as well as a protocol for recall should the need arise Together with our legal counsel and The Intertek Group, a world leading provider of quality and safety services and other accredited Third Party Testing laboratory, we have identified all relevant product standards and regulations and have established voluntary standards.
While it is important to note that none of our products were designed or intended for children under the age of 12, but for use by businesses and individuals as general use promotional items, we do realize that in most cases it is prudent to treat some of our items as a children’s product and to certify that these products comply with all applicable Consumer Product Safety Improvement Act (CPSIA) safety rules, bans, standards and regulations and to issue a subsequent Certificate of Conformity which can be found for each applicable product on the website www.nolwennshop.com and clicking on the compliance link. (Note- a consolidated list of these items is attached)
All items determined by our Product Safety Team and outside counsel not to be children’s products have been reviewed and meet all applicable standards and regulations issued under the Consumer Product Safety Act (CPSA).
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CALIFORNIA PROPOSITION 65 STATEMENTS.pdf
CALIFORNIA PROPOSITION 65 STATEMENTS
All products shipped by Nolwenn LLC. into the State of California are subject to Proposition 65 (“Prop 65”). Prop 65 requires that a “clear and reasonable warning” be provided by a Person/Company in the course of doing business, who manufactures, produces, assembles, processes, handles, distributes, stores, sells, or otherwise transfers a consumer product which he or she knows to contain a chemical known to the state to cause cancer or reproductive toxicity to any person to whom the product is sold or transferred.
For exposures to consumer products, such as promotional items, the level of exposure to the listed chemical is calculated using the "reasonably anticipated rate of intake or exposure for average users of the consumer product. Companies are becoming increasingly vulnerable to lawsuits for Proposition 65 indiscretions.
Proposition 65 may be enforced by the California Attorney General, public enforcers such as district attorneys, and private plaintiffs suing in the public interest (after they have first served a 60- day notice of violation on all public prosecutors and no public prosecutor proceeds to enforce the alleged violation. A plaintiff may seek injunctive relief as well as penalties of $2,500 per violation per day. A more general California statute allows most successful plaintiffs to recover their attorneys' fees as well. It is important to note the very long reach of Proposition 65 liability. One need not be doing business in California to be in the chain of Proposition 65 litigation. Indeed, you could be a ILLINOIS distributor of products sold to you by a Corolado supplier, and your client could be doing business in New Jersey, with no California affiliation. Should one of the items you sold to your client end up in California, you and your supplier and your client could be named as defendants in a Proposition 65 lawsuit, and the venue would be in California.
Nolwenn LLC is fully committed to providing the highest quality, safest products for our clients and all our products meet applicable federal safety and warning requirements, standards and regulations as enforced by the Consumer Product Safety Commission, the U.S. Food and Drug Administration, and the Federal Communications Commission. While procedures have been established as part of our ongoing Product Safety initiatives throughout our supply chain to insure the purchase and use of raw materials that will meet Prop 65 standards, our efforts have to date been focused on the Third Party testing of our products to insure that they are in compliance with the very stringent regulations set forth by the CPSIA in regards to lead content in substrates and surface coatings of Children’s Products and Toys along with applicable Phthalate content. While lead content has been the focus of litigation in Proposition 65 cases, our current Proposition strategy has been to use our lead testing program to demonstrate that the products that we ship to California meet the Proposition 65 standards for lead.
Because we cannot test every piece of every order that we ship to California for every one of the Proposition 65 listed 750 chemicals, you may continue to have concerns about compliance with Proposition 65. If so, then the safest option is to include a label on each product that may ship to the State of California which we will do non-free of charge test upon request.
The label will read as follows and will ensure full compliance with California Proposition 65 requirements: WARNING: This product contains chemicals known to the State of California to cause cancer, birth defects, or other reproductive harm.