Keeping Up With CPSIA Clarification of covered products under Small Batch Manufacturer

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Original Post

contessacc says

Thanks, Beverly for your reply. So, what you are saying is that if that if I printed t-shirts last year with a "tree" design, but this year I print a "train", the only covered product under Small Batch Manuf. is the "tree" design if I printed 7,500 units or less. I have to test the "train" t-shirt. Same for other products.
I had understood this incorrectly. I thought that once you were a Small Batch Manufacturer covering a product (e.g. t-shirts), you could produce all your t-shirts for that year as long as you produced less thatn 7,500 units without having to test.

So, for products printed or designed on request, Small Batch Manuf. does not help a small business at all. Nor does it help for new products for this year, or new businesses.

Posted at 12:53pm Apr 27, 2012 EDT


You have it absolutely backwards. What you printed last year was basically exempt from testing as we were on a stay, IF you had something from your printer that the ink used was below the lead level allowed.

This year if you are a small batch manufacturer, you still need something from the printer that the ink is okay, as lead in paint is still on the A list. A Certificate of Conformity that the paint meets the requirements of the law is all you need. The printer can't use paint that exceeds the level anyway. If you are NOT a small batch manufacturer, or you make 7501 of the train design you personnaly would have to send the shirt off for testing .

As for custom requests or new products this year you are covered by the law, They start the clock ticking on your products when you register. They are using the $$ and quantity information from last year for qualifing as a small batch manufacturer only.

Posted at 4:43pm Apr 27, 2012 EDT

contessacc says

Beverly, thanks so much for your clarifications.

So, please just to double check. You are saying that the $$ from last year and the less than 7,500 units of whatever product from last year was just for qualifying. Once a small batch manufacturer, I can produce any product, any design in quantities less that 7,500 (7,500 count starts at 0 for each different design or type of product) and as long as I have a Certificate of Conformity from the manufacturer of the components, then I don't need to test, regardless of the design of the t-shirt or the other products.

But anything I manufacture above 7,500 units I have to send in for third party testing.

Posted at 5:20pm Apr 27, 2012 EDT

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