Keeping Up With CPSIA
Ok, so what do I need?
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I apologize for my ignorance, I had no idea what CPSIA was until today. Thankfully, my shops are still new and my items seem to be exempt from the list. For my crochet shop, I only use yarn and buttons (though if they are a problem I could just use yarn).
Where do fellow hat makers sew on a label? Also, I do not have a website, should I just use my etsy site or my email address?
I have another shop that sells baby doll diapers. The only materials used are flannel, fleece, velcro, elastic and thread. I do not believe anything there needs to be tested either. I suppose I could sew a label on *somewhere* to the diaper.
I was just throwing around the possibility of making diaper changing pads and wipes cases that would require poly fill, but again I see that is exempt.
Sorry again for my ignorance, but any tips are appreciated.
Posted at 4:10pm Apr 22, 2010 EDT
You're going to need labels if you don't have them already. I got mine from Family Graphix here on etsy. David is so nice and he does a great job. On my labels I put my shop URL address. Just to be on the safe side I wouldn't use the buttons, that's something I try to avoid just in case you know? But once you get labels sewn on you're set. Also, I sew my labels on the inside of the hat on the back. :)
Posted at 5:21pm Apr 22, 2010 EDT
Many fabrics are exempt from lead testing, except fibers & fabrics that contain metalic looking threads, screen prints, or other chemical treatments like water resistant coating. On the other hand fastners, like buttons, require test results if you can get them from the fastner supplier in the correct format with the component described, lab name listed, and the lead and if needed the phthalate levels listed in PPM that's great or you will have to contact a lab to test your supplies.
There is no exempt list for the tracking labels, if the item is for a child 13 and under then it needs a tracking label and certain durable products need mail in registration cards. Though if the label would affect the function, severly detract from the aesthetics of the product, or would be bigger than the actual product then you can label only the packaging rather than both the package and the product. Other parts of the CPSIA like phthalates testing and small parts have no exempt raw material lists and do depend in part for what ages an item is aimed for.
Here's some reading to get you started on understanding the CPSIA. (the ones with * are most important to read first)
* For the current full list of raw materials offically exempt from lead testing please read www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-dra...
* CPSIA guidance for small businesses/crafters includes a quick look guide Table : B exempt raw material list
* An update on the stay of 3rd party testing
* Tracking labels
CPSIA's FAQ page
The CPSC also has product specific laws, regulations and standards that must be followed about the way some things must be constructed in addition CPSIA which concerns mostly what components go into the making of a product. Like sleepwear must be flame retardant or form fitting, length of the ties for bibs & smocks, the sizes for blankets to be considered a recieving blanket, and many other things. Do a search using specific product names at the main CPSC website
The CPSIA main website
Webcasts for the 2 day public workshops in Dec 2009
The CPSC's age determination guideline www.cpsc.gov/BUSINFO/adg.pdf
A timeline from the CPSIA www.cpsc.gov/about/cpsia/rulemaking.pdf
Information on how this law is retro-active www.cpsc.gov/library/foia/advisory/317.pdf
Standard Operating Procedure for Determining Total Lead (Pb) in
Children’s Metal Products (Including Children’s Metal Jewelry) found at www.cpsc.gov/about/cpsia/CPSC-CH-E1001-08.pdf
Even non-metal components must be tested using destructive digestive testing read more here www.cpsc.gov/about/cpsia/CPSC-CH-E1002-08.pdf
Small Parts Regulations Summary www.cpsc.gov/BUSINFO/regsumsmallparts.pdf
Small Parts labeling
Maybe some one else has a link to a plain english version of the small parts regulations, but these 2 links are the best I have.
Here's info about small parts warnings and how they should appear in your listings / ads
www.cpsc.gov/LIBRARY/FOIA/FOIA08/brief/toygameads.pdf page 19 of the PDF has the abbreviations & page 20 of the PDF has the warning examples are in black-n-white but I believe they need to be in certain colors on the actual label for the physical product.
For some product there is dual jurisdiction under the FTC, like for clothing there are regulations regarding care & content labels and yet another type of labeling maybe required for fabric based toys.
The main FTC website
For fabric and fiber items
FTC Labeling requirements
Examples of FTC labels (about 3/4 of the way down the page)
A few products like diapers may even fall under agencies like the FDA - IF they could be confused with preemie, infant, or adult diapers.
The main FDA website
Posted at 6:59pm Apr 22, 2010 EDT
Thanks for your help! I just got to thinking that I use buttons for the closure on my mary jane shoes! I will have to think about how to get around that.
Could you use a small dot of velcro?
Posted at 10:55am Apr 23, 2010 EDT
I probably could do that...I'm not sure I would trust the stick on kind to actually stay on, so I would have to sew it on...
I found who I'm going to order tags from, which reassuring! Now, I just have to get together what I want them to say. I'm going to have to order several different tags. Some that say 100% cotton, some that are acrylic, then tags for my diapers. Ugh. I'm so totally overwhelmed with this.
I suppose I will have to take all of my listings with buttons off until I can experiment if the velcro works. I have a ton of it already since I use it for my diapers, thankfully.
Posted at 11:02am Apr 23, 2010 EDT
Wow, for some reason it never occured to me that I would have to put tags on my items. It makes sense, but does anyone have suggestions on how/where to put a tag on small, crocheted hats?
Not a clue! I'm going to work on it this weekend. I'm going to try to keep the tag as small as I can and put it at the top in the back as best I can.
You know when I look through so many of the baby hat sellers, so many have little clips and buttons and things that would need testing. I wonder how well this is known in the Etsy community? I just stumbled across it myself yesterday by chance. I have removed all my listings with buttons already. *big sigh*
Posted at 2:49pm Apr 23, 2010 EDT