Buttons or no buttons?
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Unless you obtain the CPSIA ccompliance certificate from the company that manufactures the buttons, you'll have to have the buttons independantly tested. SUPER expensive. I contacted the company that makes the buttons I use and they confirmed that the specific line I use is in compliance and emailed me their certificates. (I use buttons from Blumenthal Lansing.) They were VERY easy to work with, but I've heard others are not so friendly. A phone call or two and an e-mail tomorrow *should* get you what you need to use buttons.
Posted at 6:50pm May 2, 2010 EDT
Oh, and Blumenthal Lansing buttons are EVERYWHERE . . . very easy to get and reasonably priced. You may want to visit their website and pick some favorites, then call and make sure they comply, and then go purchase. I emailed the rep for my state and they emailed back the certificates within 12 hours.
Posted at 7:10pm May 2, 2010 EDT
Currently under the CPSIA if you can get test results from a supply's manufacturer with the lead listed in PMM (& dependant on the age group the finished product is for the phthalate levels im PPM) and link the test results to which of the finished products you make then you're good to go for issuing your GCC for your products. Remember that the component testing format or requirements can be changed at any time by the CPSIA committee or even rescinded, so check the CPSIA website frequently.
Just keep in mind that the exclusion from the small parts warnings only apply to clothing if the small part in question is part of the functionality of the clothing. If the small part is an embellishment or for decorative purposes only then it my need the small parts testing / warnings. So a button used to secure two sides of clothing together is exempt from the small parts testing and having warnings but a button used to add pizazz to a piece of clothing may need to go through laboratory testing, have correctly formated warnings directly attached to the product, and have an appropriately worded warning in the listings.
Posted at 10:15pm May 2, 2010 EDT