Who will bear responsibility for non-compliant products?
The importer (i.e. party importing product into CA) will ultimately be held responsible. However, all players in the supply chain from the raw board manufacturer to the retailer are potentially liable until the enforcement investigation determines otherwise. There is no product certification or chain of custody that will insulate anyone from an enforcement action. CARB enforcement staff will evaluate each situation on a case by case basis. It is important to note that CARB will enforce this standard through random product testing and a strict chain of custody requirement.