Am I compliant?

[Former_Member]

All of my products are made with fabric I purchase in fabric stores. My kid's waistbands are elastic. I don't use zippers, snaps, or anything metal on any of my children's pieces.

All I need are labels saying where the piece came from, when it was made, and what the materials are, right?

[Former_Member]

as I understand it, yes.

[knitwit4ever]

You do need CPSIA labels (IDing the manufacturer, location, date of manufacture...) and FTC labels for garments and other fabric products (IDing fiber content and care...).

You don't mention buttons. If you use buttons made of non-fabric, non-natural materials, they likely will need to be tested or to have the manufacturer's test results on file.

Don't forget the record-keeping needed for all the above info so you can track back to a product if required.

[Former_Member]

Right. Okay, that's what I thought. I did use buttons on one of my skirts, but I'm thinking about switching to wood, crochet, or eliminating the buttons all together (they were decorative.). Thanks guys!

[knitwit4ever]

If wood, make sure they are UNcoated. Adding any sealer/varnish coating (or metal shanks) means they must be tested. :-(

[BabyFrills]

Sorry, does anyone have an example of what the label would say or look like?

I found this: "Section 103(a) mandates distinguishing marks such that (1) the location of production (2)
the date of production and (3) cohort information for that product is ascertainable. Any
such marks should be visible and legible."

So I understand there needs to be a label, but does it have to be sewn in or just in the packaging?

Thanks from a newbie!

[knitwit4ever]

CPSIA labels have to be permanent, so that they stay with the item. For fabric/yarn items, that probably means sewn in or ironed on. Hang tags are not enough.

There are several current threads asking for/showing what people are actually doing on the labels.

[BabyFrills]

Thanks, I'll go searching.

[BabyFrills]

http://www.cpsc.gov/about/cpsia/faq/103faq.html

I make hand-crafted goods in my home. What do I need to do to be in compliance on August 14, 2009?

The Commission has received a great deal of comment and input from hand-crafters regarding the implementation of Section 103(a). As noted in the Statement of Policy, the Commission anticipates that there will be a period of education after the new requirements go into effect and expects that each manufacturer, large and small, will consider how to apply these requirements to their business.

Hand-crafters should consider the following:

1. What kind of tracking system do you currently use? You do not necessarily have to create a new system of lot, batch or run numbers to identify when you made your products, however your products and their packaging should identify your company in sufficient detail to enable a consumer to reach you so that the required information may be ascertained.


2. What information can be ascertained about your product? If someone handed you one of your products sold last year, what would you be able to tell them about the materials used? Keeping your receipts and purchase orders will help you to better know the source of your product and its components and when you began using them. Ask your fellow hand crafters if they have any tips or ideas that can help.


3. How is your product marked? If someone had one of your products sold last year, would they know who to call if there was a problem? Absent any unusual circumstances, your business name should be on your product with sufficient detail to enable a consumer to reach you. Congress recognized that there could be instances where marking a product might not be practicable, such as where the product is very small. Consider the examples outlined in the Statement of Policy where it might not be practicable to mark a product.


4. How is your packaging marked? Can a retailer of your product see from the packaging (or from the product if the product marking is still fully visible) information that they could use to take just your products from the shelf in the event of a recall?


Compliance with the new requirements will call on a number of small hand crafters to rethink the way they maintain their records and mark their products.