The consumer product world is experiencing a broad emergence of Internet-connected tech products with embedded sensors and microchips that allow them to perform tasks never before imagined. They are part of the Internet of Things (IoT) and they will eventually redefine what we consider normal.  And like many tech items that evolve from pricey retail versions to low cost promotional versions, the day when IoT products arrive in the promotional industry is likely to come soon.  Imagine a T-shirt that monitors your heart rate and then automatically adjusts the program of your treadmill, a pill box that emails you if your elderly mother forgets to take her medicine, or GPS–enabled stickers that can track anything with a Find-my-iPhonetype app.  These products and hundreds more are all possible in what our industry could call the Internet of PromotionalThings (IoPT).  In time, there are bound be IoPT features added to a wide range of industry categories – from pens to drinkware to bags to apparel – as developers find meaningful ways to reimagine the customer experience and broaden marketing opportunities.

But the benefits of IoT and IoPT may come at a price.  These connected consumer products are raising serious concerns for regulators around the globe as issues of cybersecurity and privacy abound.3  Consumers have already been subjected to hacking incidents with IoT control devices in automobiles, heart regulators, baby monitors, cameras, oil pipelines and credit card scanners, to name a few.  Promotional professionals should take the time to educate themselves about IoT now, before the products become plentiful in the industry, so that when they begin to appear you will be better able to make informed decisions and protect your clients’ brands.

Only 4% of the world was online in 1999 when Kevin Ashton, a British scientist working at Proctor and Gamble (P&G), coined the term “Internet of Things.”[1]It was the title of a presentation he gave on the use of radio frequency identification tags (RFID) for P&G’s supply chain. Ashton was convinced that life would be greatly improved if computers weren’t dependent on humans for data entry – that electronic sensors, like RFID, were much more efficient.  He wrote, “If we had computers that knew everything there was to know about things—using data they gathered without any help from us—we would be able to track and count everything, and greatly reduce waste, loss and cost. We would know when things needed replacing, repairing or recalling, and whether they were fresh or past their best. We need to empower computers with their own means of gathering information, so they can see, hear and smell the world for themselves, in all its random glory. RFID and sensor technology enable computers to observe, identify and understand the world—without the limitations of human-entered data.”

That same year, Neil Gross wrote in Business Week, “In the next century, planet Earth will don an electronic skin. It will use the internet as a scaffold to support and transmit its sensations. This skin is already being stitched together. It consists of millions of embedded electronic measuring devices: thermostats, pressure gauges, pollution detectors, cameras, microphones, glucose sensors, EKGs, electroencephalographs. These will probe and monitor cities and endangered species, the atmosphere, our ships, highways and fleets of trucks, our conversations, our bodies – even our dreams.”[2] 

The Internet of Things described by Ashton and Gross is in “full flower” today, says Pew Research Center, with IoT devices pervasive in cars, voice-activated assistants, appliances, security systems, health-monitoring devices, road sensors, and personal fitness trackers.[3] And with the crop of new products introduced at the Consumer Electronics Show (CES), IoT features have begun to emerge in cameras, door locks, door bells, beauty mirrors, window blinds, toothbrushes, hairbrushes, wine bottle sleeves, umbrellas and dozens of other products.[4]  The research firm Gardner estimates that 8.4 billion connected “things” are in use worldwide in 2017 and will grow to more than 20 billion by the year 2020.[5]

But according to Pew, “the very connectedness of the IoT leaves it open to security and safety vulnerabilities.”3It is these vulnerabilities that fuel regulators’ concerns.  At the November 2017 ICPHSO International Training Workshop held in Tokyo, Japan, regulators from the U.S., Europe and Japan participated in panel discussions on IoT security risks. Anne Marie Buerkle, Acting Chair of the U.S. Consumer Product Safety Commission (CPSC) addressed the issue directly in her keynote stating that cybersecurity in IoT devices has become one of CPSC’s highest priorities and is specifically noted in the Agency’s 2017 Report on Emerging Technologies.[6]  “But we cannot solve these issues by ourselves,” Buerkle said.  To address them successfully, she emphasized, will take a coordinated effort by regulators worldwide.  But this will take time as the issues are complex, the opportunities for collaboration are limited and there are many more questions than answers.

Examples of the safety issues CPSC is concerned about were identified in a hacking contest staged at the August 2016 Def Con Conference in Las Vegas.  Def Con is the longest running computer security conference in the world, attracting more than 20,000 hackers and IT professionals annually.  A month later, Def Con announced that 47 new vulnerabilities affecting 23 devices from 21 manufacturers were identified at the conference, allowing hackers to open locks, reprogram thermostats, freeze water pipes, and take control of a wheelchair, among others.  Fred Bret-Mounet, a researcher who found some of the issues stated, “I can shut down the equivalent of a small to midsized power generation facility or I can use that device as a Trojan within a target’s network to spy on them.”[7]

The vulnerabilities identified at Def Con have been attributed to a variety of predictable causes: poor design decisions, coding flaws, hard-coded passwords, back doors, inadequate testing, rush to market, lack of standards and regulations, and the lack of cybersecurity expertise.  These vulnerabilities are already showing up in the marketplace.  In New York City, in January 2016, the Department of Consumer Affairs issued a consumer warning about baby monitors that provide easy access for predators to watch or even speak to unsuspecting children, and the department announced that it had filed subpoenas against several major manufacturers of video monitors all of whom market their devices as secure.[8]  The risk of these types of vulnerabilities appearing in IoPT devices could be significant since our industry has little experience with cybersecurity and many of the factories that develop promotional products are small, with limited resources and with fast-track development cycles that sometimes skimp on performance testing.  Low cost and speed to market are often their defining objectives.

At the Tokyo ICPHSO conference, one of the expert panels focused on solutions – ways that IoT devices could be made more secure – and whether existing cybersecurity standards from standards organizations like ISO, IEC and UL are robust enough for IoT. Stephen Brown, Director of Innovation at the global test lab CSA Group, argued that existing cybersecurity standards are adequate if products are tested at qualified labs and subjected to comprehensive testing at each stage of their development.  But the testing protocol Mr. Brown advocated was extensive and may only be affordable for mega corporations.  David Kosnoff, VP of Quality Assurance for Hasbro, approached the problem from the manufacturer’s perspective and spoke about the need for cybersecurity training of everyone involved in the design and development of IoT products.  He also advocated enhancing Failure Modes Effects Analysis (FMEA) to include cybersecurity.  FMEA is a standard QA tool that manufacturers use to identify all the ways a product may might fail as a critical step in designing out defects in the product development stage.

Left unanswered are many questions our industry will have to deal with as new IoPT products hit the market. Without even considering privacy issues, the cybersecurity questions are extensive.  What is the responsibility of suppliers and distributors when vulnerabilities are discovered?  How will they handle registering users of IoPT devices so that software and firmware can be updated with patches?  How will suppliers develop firmware and software patches (to remedy vulnerabilities) without having in-house expertise in circuit board design, microchip programming and other intricacies of IoT devices?  Whose responsibility will it be to pay for these fixes and for how long? Will there have to be a new provision added to Section 15(b) of the Consumer Product Safety Act requiring companies to report on security breaches?  How will CPSC and other global regulators treat IoT vulnerabilities for product recalls?  And how will all of this impact recall insurance policies and premiums?  These questions and many more should be adequately addressed before the industry jumps into the deep end of the pool with IoPT devices.

So while it will ultimately be very cool to have a lunch box that can send an alert if peanuts are within 50 feet, a child’s backpack that allows a worried mom to track her elementary school child, or pens that can automatically notify the advertiser to send out a new refill when the ink is running dry, you should take the time now to implement an education program in your company to learn about the technology, the cybersecurity issues, the privacy issues, the regulatory issues and how you will evaluate products and vendors when these type of products come to market.

IoT PRODUCT/SERVICE CERTIFICATION OPTIONS
Standard	Scope	Int’l Certification
ISO 27000 Series	Information Security Management System including SDLC and incident management	Y
IEC 62443 Series	Cyber Security Management System including product security and SDLC	Y
NIST 800-53	Cyber Security Management System *US Only	N
UL 2900	Product testing and evaluation	N
*Courtesy of CSA Group

——————————————————————————————————————-

[1]Ashton, Kevin, “That ‘Internet of Things’ Thing,” http://www.rfidjournal.com/articles/view?4986

[2]Gross, Neil, “The Earth Will Don an Electronic Skin,” Businessweek, 1999.

[3]Rainie, Lee and Anderson, Janna, “The Internet of Things Connectivity Binge: What Are the Implications?” Pew Research Center, http://www.pewinternet.org/2017/06/06/the-internet-of-things-connectivity-binge-what-are-the-implications/

[4]O’Donnell, Lindsey, “20 Crazy Connected IoT Products At CES 2017”, http://www.crn.com/slide-shows/internet-of-things/300083379/20-crazy-connected-iot-products-at-ces-2017.htm, January 12, 2017.

[5]Gartner Press Release, “Gartner Says 8.4 Billion Connected “Things” Will Be in Use in 2017, Up 31 Percent From 2016,” https://www.gartner.com/newsroom/id/3598917, February 7, 2017.

[6]Staff Report, “Potential Hazards Associated with Emerging and Future Technologies,” U.S. Consumer Product Safety Commission, January, 2018.

[7]Constantin, Lucian, “Hackers found 47 new vulnerabilities in 23 IoT devices at DEF CON”, IDG News Service, https://www.csoonline.com/article/3119765/security/hackers-found-47-new-vulnerabilities-in-23-iot-devices-at-def-con.html, September 13, 2016.

[8]NYC Consumer Affairs Press Release, “Consumer Alert: Consumer Affairs Warns Parents to Secure Video Baby Monitors,” http://www1.nyc.gov/site/dca/media/pr012716.page, January 27, 2016.

At a recent industry event, a top 40 supplier told me about a USB phone charger his company added to its line.  “The factory with the UL-compliant model was more expensive, so we decided to go elsewhere and buy a cheaper one,” he said. “With so many inexpensive adapters on the market, we didn’t feel that our customers would be willing to pay the higher price.”

Of all the product safety imperatives in the promotional products industry, none is more widely misunderstood than compliance with “voluntary” or “industry consensus” standards.  Most distributors and suppliers are either unaware of the critical importance of voluntary standards in the United States or under a misconception that compliance with voluntary safety standards is optional.  But the CPSC doesn’t agree.  Speaking at PPAI’s 2015 Product Responsibility Summit, Marc Schoem, Deputy Director, Office of Compliance and Field Operations for the U.S. Consumer Product Safety Commission (CPSC), said “The Commission expects all consumer products – including promotional products – to be fully compliant with applicable voluntary standards.”  Perhaps most surprising to the 190 attendees was Mr. Schoem’s follow-up opinion that voluntary standards often don’t go far enough and that CPSC generally regards voluntary standards as a minimum.

Standards Development – A Private Sector Process with Government Participation

Voluntary standards, developed by private sector participants, have provided the backbone of product safety in America for 100 years.  The American National Standards Institute (ANSI) – a non-governmental organization (NGO) – is responsible for overseeing and accrediting voluntary standards in the United States.  The individual standards are developed under the supervision of more than 200 standards development organizations such as ASTM International and Underwriters Laboratory (UL).  The U.S. Toy Safety Standard, F-963, well-known to our industry since Congress made it mandatory in the Consumer Product Safety Improvement Act (CPSIA), is an example of an ASTM standard developed by its F15 committee.  UL2054, the lithium-ion battery standard in the U.S., is an example of a UL standard.  Government regulators have long preferred to have industry police itself through voluntary standards, however, Congress took the additional step of memorializing that preference in The National Technology Transfer and Advancement Act of 1995 (NTTAA).  That legislation requires federal agencies to defer to standards developed by “voluntary consensus standards bodies” whenever possible and to participate in the process.  However, governmental participants on standards development committees do not normally have a vote.

How a Standard is Developed

To understand how a standard is developed, consider the genesis of ASTM’s new liquid laundry packet standard.  Soap manufacturers had developed a novel method of packaging liquid laundry detergent into convenient, individual-use packets.  While the attractive and colorful packets were an instant hit with consumers, they were mistaken by many children as candy.  Before long, hundreds of poisoning cases were reported at hospitals and poison control centers nationwide.  Responding to the surging incidents, CPSC sent a letter to ASTM asking that a committee be formed to develop a standard for laundry packets that would eliminate or minimize the danger. ASTM invited all interested parties – manufacturers, retailers, government regulators, consumer advocates, trade associations, technical experts, academics and others – to meet to discuss the hazard.  As a result, the Liquid Laundry Packet Subcommittee F15.71 was formed, a chair was selected and the challenging process of agreeing upon a comprehensive standard was begun.

Depending on their client’s or employer’s role in the stream of commerce, each of the participants on a standards development committee has priorities for what will ultimately be included or excluded from the standard.  Accordingly, the discussions can become protracted and contentious.  It took a full two years for the laundry packet subcommittee to work through issues including child-resistant packaging, candy-like graphics, and whether a foul-tasting coating could be added to the outside of the packets to deter ingestion.  It is up to the subcommittee chair to find common ground, build consensus and get the participants to agree on key elements.  Like any collaborative process, no participant is likely to get 100% of what he or she wants.  Even after a standard is developed and published, its development committee continues to meet periodically to evaluate injury data and consider whether that standard needs to be revised or updated.

The Alternative is Mandatory Regulation

U.S. reliance on voluntary standards is a major benefit to American business.  Consider the alternative.  Would you rather have regulators decide the mandatory requirements for your products without your input or interest in mind or would you prefer a consensus process where industry participants get a seat at the table in every stage of the process and have a vote in the final outcome?  The answer seems obvious but sometimes it has taken the threat of regulation to prod market leaders to agree on a restrictive standard.  In February 2015, when the liquid laundry packet subcommittee had not yet achieved consensus on a new standard, U.S. Senator Dick Durbin (D-IL) and U.S. Representative Jackie Speier (D-CA) lit a fire under the subcommittee by introducing a bill in Congress entitled The Detergent Poisoning and Child Safety Act requiring CPSC to set mandatory safety standards for liquid laundry packets.  But in September 2015, immediately after the ASTM’s laundry packet subcommittee reached consensus and published its new standard, these same legislators issued a press release commending the subcommittee for the new rules stating that “we will be monitoring their effectiveness and evaluating whether further action or legislation may be needed.”

A similar example occurred in September 2011, prompted by the CPSC.  Acting on a petition by four consumer advocacy groups to ban toy jewelry containing more than trace amounts of cadmium, CPSC directed its staff to begin drafting a notice of proposed rulemaking – the first step in developing a mandatory regulation – unless an effective voluntary standard could be developed on an expedited basis. As a result of this pressure, in just two months, an ASTM subcommittee published Standard Specification for Consumer Product Safety for Children’s Jewelry (ASTM F2923-11) and related provisions of the toy safety standard were revised the following month.  Six months later, after getting confirmation from CPSC staff that the new voluntary standard was adequate, and that there was substantial compliance with the voluntary standard, the Commission voted to withdraw its directive for a rulemaking.

“Substantial compliance” is indeed a critical factor in the success or failure of a voluntary standard.  Lawmakers and regulators do not hesitate to take matters into their own hands by issuing mandatory regulations if they determine that voluntary standards are not working effectively to protect consumers. In the summer of 2007, millions of toys were recalled, many because they didn’t meet the ASTM voluntary toy standard.  An angry Congress responded by enacting the CPSIA which made the toy safety standard mandatory.  Voluntary standards can also be “incorporated by reference” into U.S. law which effectively does the same thing – makes a voluntary standard mandatory.  This is a common practice across government agencies.  The National Institute of Standards and Technology (nist.gov) maintains an online database of all voluntary standards that are incorporated by reference into federal regulations.[1]

Voluntary Standards, Mandatory Compliance

Don’t let the word “voluntary” fool you.  Voluntary standards can be enforced just like mandatory standards.  Even if a voluntary standard is not incorporated by reference into a federal law, agencies are able to use other statutory authority to enforce it.  UL 588 is the designation for the long-established voluntary Standard for Seasonal and Holiday Decorative Products.  In a June 2015 letter, CPSC warned that any products not meeting the three “readily observable safety characteristics” set forth in UL 588 – minimum wire size, sufficient strain relief and overcurrent protection – would be considered as having a “Substantial Product Hazard” under Section 15 of the Consumer Product Safety Act and either refused admittance into the United States or ordered to be recalled.

What About The Customer?

We’ve talked about how voluntary consensus standards are the backbone of product safety in the U.S. and about how serious our regulators are about compliance with these standards.  But what about our customers?  What level of safety do they expect?  What duty do we owe to them to ensure that the logoed products they give away to spread goodwill are safe and compliant with applicable standards?  To the supplier who decided not to carry the UL-compliant phone charger, would distributors still sell this product to their end-buyer customers if they knew it wasn’t compliant with the prevailing standard?  Would they care?  What if the supplier’s website was fully-transparent and said, “This model has not been tested to the UL standard because we didn’t think distributors would pay the higher price for a tested model.”  Would distributors still buy the product?  What about the distributor’s customers – the end-buyers whose names, logos and reputations are on the line with the products they give away?  Do you think these end-buyers are aware they are getting a cheaper, non-compliant model or do you think they expect that the promotional products they buy are compliant with all applicable safety standards?  What if an end-buyer gives away one of the non-compliant adapters and it causes a fire?  Who would blame whom?  What would be the distributor’s and end-buyer’s expectations?

Are Promotional Products Subject to Voluntary Standards?

There are many products in the promotional products industry covered by voluntary standards.  In addition to phone chargers and children’s jewelry previously discussed there are standards for products in most industry categories including apparel, drink ware, writing instruments and, of course, technology and electronic products.  Rechargeable lithium-ion mobile power banks present a challenging example of a wildly popular promotional item with potentially serious product safety risks.  Compliance for these products is more complicated than many because there is one voluntary standard for the lithium-ion cell, another for the assembled power bank and yet another for safe transportation of the assembled power bank.  Don’t overlook tech products that contain internal lithium-ion batteries as well, such as rechargeable Bluetooth speakers.  Unfortunately, many suppliers and distributors of these products do not have an understanding of these standards and many of the products on the market have not been tested to the applicable standards.

Best Practices: What Should Suppliers Do?

Suppliers should have a detailed, step-by-step risk assessment process for every product in their line.  Learning the voluntary standards that are applicable for each product is one of the most important steps of the risk assessment process.  Third-party testing labs can be a good resource for this information as are the websites of standards organizations like ANSI, ASTM and UL.  Concerning Mr. Schoem’s point about exceeding the minimum, each time you evaluate a new product, you should determine with your compliance and product development teams whether the voluntary standards applicable to that product go far enough.  Have the standards been updated to deal with current products, current technology and consumer behavior?  Have any new risks emerged?  What are other manufactures and suppliers doing with similar products, both inside and outside of our industry?  What are customers asking for and expecting?  Have there been any recent recalls for this category of product?  And don’t forget to consider foreseeable misuse of the product.  Informed by the insights you gain from investigating these issues, establish and document the specifications and standards you expect your product to meet.  Then, after your product is designed and manufactured, the next step is what standards developers call “conformance assessment.”  At the Product Responsibility Summit, Ken Boyce of UL said, “Without conformance assessment, voluntary standards are just good ideas.”  Conformance assessment includes all of the verification processes including self-testing, surveillance, inspection, certification, auditing, and third-party testing to ensure that the product meets your specifications and the standard.  One last note for your marketing team:  It’s very helpful for distributors if the supplier’s website and catalogs communicates the standards that the product complies with and where the distributor can obtain copies of the test reports.

Best Practices: What Should Distributors Do?

For distributors, don’t presume that a product is compliant just because a supplier is large, prominent or carries industry certifications.  Get to know the compliance people at each of your suppliers.  Ask lots of questions, particularly for high risk categories like consumer electronics, products to be used by children, food products, health care products and personal care products.  Are there any voluntary standards applicable to the product?  Does the supplier have current third-party testing and adequate documentation to confirm that the product complies?  Ask the same question of different suppliers and to a lab partner to be sure that you’re getting consistent and accurate answers.    Most important, don’t assume anything.  Your customers expect the products they buy will comply with all standards, whether or not it’s the law.  They are relying on you, your integrity and experience; don’t let them down.

[1] http://www.nist.gov/standardsgov/stnds-in-laws-policies-and-regs.cfm

Having recently returned from PPAI’s highly acclaimed Product Responsibility Summit, I am more and more convinced that our industry is inching closer to a tipping point where the standards required for a successful promotional products business are materially different than those of just a few years ago. I raise this point now, before it becomes universal, because as chair of our 11,000-member association, it is my hope that all PPAI members emerge as winners in this brave new world. However, I fear that unless everyone ramps up their efforts to evolve, that may not be the case.

At the beginning of this year’s Summit—PPAI’s most well-attended educational event ever—I asked the 185 attendees how many had “compliance” in their job title. Except for the CEOs and service providers in the room, the answer was nearly everyone. Wow! What a sea change this is from our first Product Safety Summit five years ago when almost no distributors or suppliers had dedicated compliance staff and the industry was still trying to sort out what product safety meant. Things have changed indeed. In our session on best practices, we heard from large and small distributors alike who vet supplier compliance thoroughly, seek out independent certification of suppliers and actively direct orders to suppliers who have the most comprehensive compliance programs. And since rigorous compliance, factory audits and product testing is very costly, the price of entry for success at the highest level in our industry has gone up dramatically.

Change is not just occurring in compliance. Technology is rewriting the rules for success in our industry just as it is in all others. While overall sales in our industry grew by a scant 1.1 percent in 2014 versus 2013, online sales grew by a massive 33 percent in that same period. Direct online promotional product sales rose to $800 million in 2014—four percent of total industry sales—and will continue to grow as more industry players and, quite possibly, well-funded non-industry players, offer compelling online solutions.

This is consistent with an April 2015 Forrester Research study entitled “Death of a (B2B) Salesman” which predicts that a million business-to-business salespeople in the United States will lose their jobs by the year 2020 as more and more customers opt for self-service e-commerce websites. In a related article, Forbes magazine noted that nearly 75 percent of B2B buyers now say that buying from a website is more convenient than buying from a sales representative. Further, 93 percent say they prefer buying online rather than from a salesperson when they’ve decided what to buy.

Forrester contends that salespeople who are essentially “order takers” will fare the worst while those engaged in “consultative selling” will do the best. The Forbes article added that in a technology-driven world, companies will need to become “omni-channel,” meaning they need to provide the seamless purchasing channel their customer prefers—whether by an in-person sales call, web browser, tablet or smartphone, telephone, Skype, chat, text or email, social media, or through a brick and mortar showroom.

Harvard Business Review added a hopeful perspective on the Forrester Research in an article titled, “B2B Salespeople Can Survive if They Reimagine Their Roles.” In part, the article said: Today’s field salesperson should be an educator, negotiator, consultant, solution configurator, service provider and relationship manager. They are integral to discovering the “something more” that customers want. As customers will tell you, a salesperson must add value by becoming part of the product or solution.

In a full-day strategic planning session earlier this year, David Nicholson, president of Polyconcept North America (PCNA), led the PPAI board in a deep-dive discussion into these and other disruptive changes that are already happening or potentially threatening our businesses, our industry and our association. The discussion focused on changes resulting from the combination of globalization, technology and demographics, and the distinction between our well-established supplier/distributor industry and the overall promotional products marketplace.

Today’s promotional products buyer has many options outside of our industry. Aside from domestic options through new players such as Amazon, Café Press, Zazzle, VistaPrint and Custom Ink, there are many overseas options. For the past few years, there has been a “Small-Order Zone” at the Hong Kong Gifts and Premium Fair with hundreds of vendors offering small- quantity, quick-ship services. Alibaba and other Asian portals provide U.S. buyers with instant access to thousands of Chinese factories, but without the quality and compliance oversight of a PPAI member.

It isn’t just purchasing options that are evolving—so are our customers. Millennials—the youngest members of our industry who came into adulthood after the year 2000—have different norms, values and buying habits than their baby boomer parents. Technology isn’t something they’re just learning to deal with—it’s part of their DNA. They expect to be able to buy online, do research about you and your products and share their experience with all of their friends. They expect your website to work as well as Amazon with all the same rich features they’re used to, including comparisons, reviews and one-click ordering. They’re socially conscious. They care that you’re buying from factories that pay employees fairly and have safe working conditions. They expect the products you’re selling to be safe.

Webster defines tipping point as “the critical point in a situation, process or system beyond which a significant and often unstoppable effect or change takes place.” No one can deny there are great changes occurring in our industry. Some of us are experiencing them sooner or to a greater degree than others. How close is the tipping point at which the industry as we know it is irreversibly altered? How are you preparing by updating your business practices, by investing in technology and by educating your team, as so many did at the Product Responsibility Summit?

Whatever the changes, PPAI will continue to be your closest ally in providing support, education and affordable tools. I hope you will take advantage of all your Association offers, that you will respond to whatever challenges the future brings and that you will continue to have great success in the promotional products business for many years to come.