Becoming CPSIA Compliant--Cloth Diapers

[Former_Member]

I have been giving myself a headache trying to learn how to become CPSIA Compliant. Now I have a few questions. I make cloth diapers. I have registered with the Small Batch registry. All components of my product are either tested (snaps and PUL) or exempt (thread, fleece and elastic). My questions are:

1. Do I need a COC for myself that lists the testing done by the companies I purchased the snaps and PUL from? Or do I simply need to have the certificates on hand?
2. I want to sell my product to retailers as well as direct sales to consumers. Because of this, do I need to have a my own COC to give to the retailers? Or do I just give them the certificates from the snaps and PUL manufacturers?
3. To be compliant with labeling, I have not been able to find a clear answer as to whether or not diapers need to have the full CPSIA label permanently affixed to the diaper. I thought I read somewhere that they were exempt but I cannot find that clearly stated again. Do diapers need the CPSIA label?

Thank you!

[FayeMaloneDesigns]

Since you want to sell to retailers:

1. Keep copies of testing done by other companies, and any COC's you have from them. Keep all the infor on testing you can get.

2. You will need to make up your own COC's for each retailer to accompany each shipment. What each retailer may require may vary. Some large retailers will make you test yourself they don't care about exemptions, That's for you to negotiate with the retailer. Mom and pop stores may or may not understand about the CPSIA.

3. I know of no exemptions from labeling for diapers. I think they are exempt from FTC labeling, but CPSIA Tracking labels are entirely different.

[WHIMSICALandWITTY]

This group should help a lot too!

https://www.facebook.com/groups/227360430739322/

[Former_Member]

What is the difference between being CPSC compliant and Small Batch Manufacture Registry? I've seen several cloth diaper boutiques say they are either one of these so which is needed?

[FayeMaloneDesigns]

Saying you are compliant should always mean you follow all the CPSIA law including testing if needed, recordkeeping, and labeling. Being a registered Small Batch Manufacturer is not mandatory, but if you are not, you are responsible for testing at your own expense, you may not use the testing results from any of your suppliers.