A cargo ship.

WASHINGTON — A coalition of industry trade groups has outlined concerns to lawmakers over a proposal by the Consumer Product Safety Commission to impose user fees on imported consumer products to pay for a pilot import surveillance program.

The groups, representing a broad swath of apparel brands, retailers, toy manufacturers and other consumer products, recently sent a letter to the chair and ranking member of a House Committee on Appropriations subcommittee that is in the process of crafting spending legislation for the agency’s fiscal year 2017 budget.

In addition to concerns about the proposed user fee, the groups also pointed out the CPSC’s lack of industry engagement on other programs and proposed rules, such as an import targeting program known as the Risk Assessment Methodology.

“We…remain concerned that CPSC continues to request authorization for user fee authority to pay for the import surveillance program,” the groups, including U.S. Fashion Industry Association, National Retail Federation and American Apparel & Footwear Association, said in the letter.

They said CPCS’s import surveillance program and RAM are “core CPSC functions and as such should be funded through the normal Congressional appropriations and oversight process and not through user fees.”

In its funding request, the CPSC, which oversees the safety of imported consumer products, recalls and testing, is asking for $3 million in additional funding for fiscal year 2017 that begins on Oct. 1 for an import surveillance pilot program to add 15 full-time staff  for the new program and expand CPSC’s presence at U.S. ports.

“This increase in staff will enable the CPSC to have staff coverage at 7 percent of U.S. ports, comprising 65 percent of all consumer-product import entry lines,” the agency said in its budget request in February.

The additional funding would cover salary costs, field equipment for surveillance and associated costs.

“The CPSC is also requesting that Congress authorize an import surveillance user fee as part of the full-year 2017 appropriations process,” the agency said.

Implementation and collection of the user fee would require rule-making on the part of the CPSC, while the use of fee collections for import surveillance costs would have to be approved by Congress annually. The agency said if it is approved by Congress, the target implementation date would be the beginning of fiscal year 2018.”

Jonathan Gold, vice president of supply chain and customs policy at the National Retail Federation, said CPSC has made the request for user fees in the past, but Congress has not approved them.

“We’re really concerned about a new user fee being put in place and not knowing how will it be used or whether it will be used for the intended purposes,” Gold said.

According to the CPSC, more than 192,000 importers brought goods into the U.S. under CPSC’s jurisdiction with an estimated value of $754 billion during fiscal year 2015, a fact cited by Gold in recent Congressional testimony.

“That amounts to more than $2 billion worth of consumer product imports per day,” Gold said at the hearing. “Even seemingly small changes to what may be required for the entry of imports can cause enormous burdens and disruptions in this vital trade.”

Julia K. Hughes, president at the U.S. Fashion Industry Association, said “There are already a number of user fees on [imported] products — harbor maintenance fees and merchandise processing fees. Historically, the industry was told the fees would go directly to fund improvements but that didn’t [always] happen. It ends up going to the general Treasury and there is skepticism about adding more user fees” that the industry does not have engagement or input on.

Another concern was raised about the CPSC’s RAM program, which the industry supports. It is used to analyze import data and identify high-risk imports.

“While we support the RAM, industry still believes additional coordination and consultation with all affected trade stakeholders is needed for further development and implementation of the system to ensure legitimate commerce and entries of compliant products are not stopped or unnecessarily delayed during the CPSC’s import screening process,” they said. “As CPSC has piloted their import surveillance programs, we have seen that the agency’s efforts have resulted in significant and unnecessary delays on compliant goods. Importers are not provided information on why their shipments are targeted and are frustrated by the CPSC’s lack of communication on this issue.”