Tis the season for product safety awareness

Despite the U.S. Consumer Product Safety Commission (CPSC) undergoing many changes in 2025, some holiday traditions have stayed the same. The agency continues its annual year-end focus on product safety as people shop for holiday gifts for their loved ones.

This year, the CPSC is encouraging consumers to buy from trusted sellers—both in person and online—to reduce the risk of purchasing a counterfeit or unsafe product. The Commission also provided safety tips regarding decorating for the holidays and purchasing gifts, especially toys.

While the CPSC’s press release highlights measures for consumers to take, it also provides some insight for manufacturers and retailers into potential oversight and enforcement risks.

Keeping the holidays merry and bright

Over the past few years, consumer product regulators have increasingly focused on online retailers and their responsibilities for keeping defective or unsafe products off the market. Across jurisdictions, operators of online marketplaces face stricter scrutiny and greater responsibility for the products listed on their websites. 

The EU recently finalized its new Toy Safety Regulation, which introduces additional requirements for online marketplaces around labeling and safety warnings. In July, the UK’s Product Regulation and Metrology Act 2025 entered into force. It also includes considerations for online sellers. Both jurisdictions are also expanding obligations for stakeholders across the entire lifecycle of a product. 

In the U.S., the CPSC has demonstrated that it expects retailers and other service providers to share responsibility with manufacturers for faulty or dangerous products. Last year, the CPSC unanimously voted to designate a leading online marketplace as a distributor of third-party products under the Consumer Product Safety Act (CPSA). That means the company has a legal responsibility for recalling unsafe products and issuing notifications to the public, even for items sold by third-party sellers on the company’s website. That litigation concluded earlier this year, with support from Acting Chairman Peter Feldman. So even with the changes to agency leadership, strong monitoring of online sales is expected to continue.

Manufacturers and retailers should be prepared for additional scrutiny as consumers’ online spending increases during the holidays. While the operators of online marketplaces now share some responsibility for addressing unsafe products, it is first and foremost the duty of the manufacturer and retailers. In any recall or remediation scenario, companies need to act quickly and thoughtfully to ensure they address noncompliance, are communicating transparently with regulators and customers, and are maintaining product safety standards.

Checking the list twice

There are many steps companies should consider during the holidays—and any time of year—to ensure they wind up on the nice list. This includes regularly auditing their supply chain to ensure all suppliers and partner companies are in compliance with applicable regulations and that the end products are free of counterfeit or unsafe parts.

Companies should also make a concerted effort to review and update their recall and communications plans for in-market crises of all kinds. In addition, they should regularly practice these strategies to ensure employees know their roles, potential shortcomings have been identified and addressed, and the company will remain on regulators’ good side.

Regulatory requirements are shifting and new risks are emerging at a rapid pace. Companies must adapt how they respond. In addition to being ready for a voluntary recall, can they manage the impact of a unilateral press release from the CPSC?

The holidays are a time of good cheer—don’t let a lack of foresight or preparation land your company on the naughty list. 

Trusted by the world’s leading brands, Sedgwick Brand Protection has managed more than 8,000 of the most time-critical and sensitive product recalls in 150+ countries and 50+ languages, over 30 years. To find out more about our product recall and incident response solutions, visit our website here.