Amazon compliance letter regarding CPSIA

This popped up on an independent booksellers mailing list I'm part of. It was sent to a small publisher that sells products to Amazon.com So yes, the big boys ARE making smaller vendors comply.

This is a dense letter, so I'll pull out a quote I think is the key bit here. Regarding providing Amazon with the lead certificate:
"Any children's products which are not so confirmed are subject to removal from the Amazon.com catalog, and Amazon.com will be entitled to return to you for a full refund (including shipping costs)..."

Sorry for bad formatting here, original letter had some HTML that doesn't work here.

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From: "Amazon.com Vendor Central" <vendor-central@...>
Date: Wed, 7 Jan 2009 00:13:21 -0800 (PST)
Subject: Regarding Consumer Product Safety Improvement Act of 2008 - Lead and Phthalates


Dear Amazon.com Advantage vendor:

We previously wrote to you on November 19, 2008 regarding requirements imposed by the Consumer Product Safety Improvement Act of 2008 (the 'Act') with respect to safety warnings applicable to children's toys and games.

This message outlines the steps Amazon.com will require vendors to take to confirm their compliance with another aspect of the Act, namely, its provisions limiting lead and phthalate content of children's products.

We will need your response by January 15, 2009 regarding lead and phthalate content compliance. If you supply any children's products (that is, any products intended for children 12 and under) to Amazon.com, you will need to submit a completed spreadsheet listing those products and the applicable compliance information (a blank spreadsheet can be found in the Resource Center of your Advantage account), and return it to us via the Contact Us form.
This issue is described in further detail below, along with information about what you need to do to ensure the compliance of your products offered on Amazon.com.
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Background
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The U.S. House and Senate have passed the Consumer Product Safety Improvement Act of 2008 (the 'Act'), and on August 14, 2008, President Bush signed the Act into law.
We expect that all Amazon.com vendors will ensure that their products are compliant with the Act in accordance with all applicable effective dates. Specific provisions of the Act discussed in this letter are for ease of reference only. Specific provisions of the Act discussed in this letter are for ease of reference only. Further information on the Act is available on the Consumer Product Safety Commission ('CPSC') website at www.cpsc.gov <http://www.amazon.com/gp/r.html?R=323D51USB6BJL&C=3K0PYQSELDMEO&H=2b9XEdt2pQt1Zyl8SwZmAjpiMM0A&T=C&U=http%3A%2F%2Fwww.cpsc.gov> .
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Product Content Limits
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The Act prescribes strict limits on the content of certain materials in products intended for children, including lead and phthalates. In particular:
* Effective February 10, 2009, the Act prohibits the sale of children's toys and child care articles with concentrations of more than 0.1 percent of di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), diisodecyl phthalate, (DIDP), or di-n-octyl phthalate (DnOP).
* The Act mandates a phased-in ban on lead in substrate for all children's products, requiring that lead levels be reduced to a maximum of 600 parts per million by February 10, 2009; 300 parts per million by August 14, 2009; and 100 parts per million by August 14, 2011. Electronic devices and inaccessible component parts will be subject to rules to be issued by August 14, 2009.
* The Act also reduces permissible lead in paint content from 0.06 percent to 0.009 percent (effective August 14, 2009), which may be lowered further by administrative action.

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What you need to do
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We expect that vendors will familiarize themselves with the effective dates of each applicable limit. In order to minimize the difficulty of tracking multiple versions of the same product through the supply chain, it is highly advisable for manufacturers to promptly eliminate or phase-out product offerings which do not or will not comply with the most restrictive limits described above, well before such limits take effect.
Follow the instructions located in this file, download and complete the spreadsheet and return it to us as an attachment to a Contact Us form, using Issue: Item Detail Page; Subissue: Consumer Product Safety Improvement Act.
If all of your products are compliant with the lead and phthalate limits according to the table below, submit a Contact Us, using the instructions above, with the following statement 'We, [Vendor Name], certify that all of our products are compliant with the lead and phthalate limits effective as of August 14, 2011 as defined by the Consumer Product Safety Improvement Act of 2008.'
If some of your products are not compliant by any of the dates below, you must complete the spreadsheet located in the Resource Center of Vendor Central, as stated above. Only one spreadsheet needs to be completed.
As of each date set forth in Column III of the table below, each vendor must confirm and report to Amazon.com that all of your children's products (i) in Amazon.com's inventory, as reported to you in Vendor Central as of such date, and (ii) in transit or shipped to Amazon.com on or after such date, will comply with applicable limits set forth in Column I.
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Specific Guidelines:
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Limit Phthalate ban:
Effective Date of Limit per the Act 10-Feb-09; Products shipped to Amazon.com must comply by 30-Nov-08; Noncompliant products are subject to return to Vendor 15-Jan-09
Lead 600 ppm:
Effective Date of Limit per the Act 10-Feb-09; Products shipped to Amazon.com must comply by 30-Nov-08; Noncompliant products are subject to return to Vendor 15-Jan-09
Limit Lead 300 ppm:
Effective Date of Limit per the Act 14-Aug-09; Products shipped to Amazon.com must comply by 14-Apr-09; Noncompliant products are subject to return to Vendor 1-Jul-09
Limit Lead paint 0.009:
Effective Date of Limit per the Act 14-Aug-09; Products shipped to Amazon.com must comply by 14-Apr-09; Noncompliant products are subject to return to Vendor 1-Jul-09
Limit Lead 100 ppm:
Effective Date of Limit per the Act 14-Aug-11; Products shipped to Amazon.com must comply by 14-Feb-11; Noncompliant products are subject to return to Vendor 1-Jul-11

Please put your vendor name in the subject field of the email when you respond in any case.
Any children's products which are not so confirmed are subject to removal from the Amazon.com catalog, and Amazon.com will be entitled to return to you for a full refund (including shipping costs) any non-compliant products which remain in our inventory as of the dates in Column IV above.
In order to minimize difficulties in inventory compliance tracking, any products which are altered to comply with a limit described in the Act must have a distinct SKU number from previous versions. These changes must be reported to Amazon.com along with a return authorization for any Amazon.com inventory of previous versions.
The Act provides that the CPSC may issue regulations providing for further limitations on the content of children's products. Vendors are responsible for tracking and complying with any regulations issued by the CPSC.
We are confident that you share our commitment to ensure the full compliance with the Act of all of your products sold on Amazon.com.
Thank you for your cooperation in this matter.
Best Regards,
Amazon.com
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Posted at 2:08pm Jan 7, 2009 EST