Buttons, yes or no?

[Former_Member]

Anyone have a clue on whether buttons count as non-metallic trim?

[Former_Member]

I think since they're plastic they're subject to the phthalate limits.

[Former_Member]

Bumping this again. Would they be subject to phthalate limits on a cardigan that is not used for "sleeping, feeding, sucking, or teething"?? It's so confusing.

[Former_Member]

wood buttons are fine, they're "natural."

[Former_Member]

Thanks. Gotta go find some wood ones I guess.

[Former_Member]

Bone used to be used for buttons too, I don't know if it still is....

[Dannielle]

there are shell buttons, too. plastic buttons can be a source of lead, too.

[Dannielle]

clarifying (because I know it sounds odd): colored plastic button can be a source of lead from the coloring, not the plastic. though even if there is some lead content, it may be low enough to be within legal limits.

when I had glass seed beads tested I was surprised to find they pretty much all contained some lead, though all far below the 600ppm limit. the darker the color got the higher the count.

[Former_Member]

No. I am not putting on any buttons except unfinished wood ones on any of my products, and no more beads. Embellishments will just be felt or fabric. Sad, but at least I can still keep going somewhat while we fight this monster. I believe velcro is exempt (but if not, mine has been tested as lead free), so all fastenings will be made with velcro.
Buttons, snaps, grommets, rhinestones, beads, etc, all have to be tested - both plastic and metal.

[StoryBlox]

Anyone looked into the small parts issue? I'm not sure if it applies to clothing but I know it applies to toys, and the rule is basically regarding anything a child could possibly find a way to swallow (there are specific sizes and dimensions laid out in the law)...

Most buttons would qualify as "small parts" so you might need a warning on anything with a button saying it's not intended for children under 4 (there's specific warning text that would have to go on your listings and on the product/packaging).

The new 3rd party testing requirements has a special section requiring 3rd party testing for small parts, and I think it's one of the exceptions to the exemption. Again, though, I'm not certain if the small parts rule applies to "anything intended for children under 12" or only to toys.

[Dannielle]

Yes, I have a rubber stamp of the official small parts warning that I use when making my packaging.

[Former_Member]

I would think that plastic buttons shouldn't be a source of phthalates, as phthalates are used to make plastics flexible and buttons are rigid. If plastic fabrics such as polyester are covered in the textile exemption, I don't see why buttons wouldn't be covered as non-metallic trim. I, however, am not an authoritative source on such things, and it's probably best to keep seeking a more definitive answer.

[Former_Member]

Would plastic buttons be included in the stay of enforcement?

[Dannielle]

the stay only means we are not required to test and we aren't required to issue GCCs...yet. We're still totally responsible for what we sell. We're liable if we sell items that exceed the lead limits or contain phthalates.

If you're not absolutely sure that what you're using is safe it might be wise to either test (even though it isn't required) or substitute with something you're sure is safe.

[Former_Member]

I contacted the manufacture of the buttons I purchase and received this letter:
"Even though our products are not specifically marketed for children we have been pro-active since 2006 in requesting certification by means of third party testing from all our vendors with regard to lead to a standard of 200 ppm.

The lab that is used to test our product is a CPSIA certified one and the tests conducted are those specifically targeted for button products.

There is an X-ray Florescence technology on the market today that is currently being used by many people to test product. We believe this was designed primarily to test for lead in surface areas like paint and can often give a false reading for an item like a button.

Please be assured that we are always concerned for customer safety and are cognizant of all the current 209 restrictions.

Blumenthal Lansing Company"

I read this as their buttons test 200ppm for lead, under the 600ppm.

Not sure if I still need to also test.

[Former_Member]

What about snaps on onesies and bibs? I just bought a bunch of these before Christmas.

[Dannielle]

craftyann says:
I contacted the manufacture of the buttons I purchase and received this letter:
"Even though our products are not specifically marketed for children we have been pro-active since 2006 in requesting certification by means of third party testing from all our vendors with regard to lead to a standard of 200 ppm.
*******************************

This sounds reassuring but, personally, I'd think twice before trusting such statements.

You have no idea how stringent their testing regimen is. Do they test every batch? One batch? Random testing?

Is the overseas factory that makes their buttons aware of when testing will occur?

Not only are you putting trust in the button company, you're also putting trust in the factory that makes their product without knowing how much oversight that factory gets.

They're telling you what their policy is but they aren't giving any information on how much effort they put into policing their policy.

I truly don't mean to be harsh or to cause panic. I just want people to really think about the risks of extending trust in this situation.

If your business is a sole proprietorship it isn't just your business at risk, it's you...and your family's assets.

[Lavender2Lace]

Is that 200 ppm per button, if so than the cumulative effect of 4 buttons goes over the limit.

Maybe that is why the CPSC is asking for testing of finished products.

Unless the findings manufacturers get their act together, I don't know what can be done for closings on children's clothing.

[Former_Member]

Lavender2Lace says:
Is that 200 ppm per button, if so than the cumulative effect of 4 buttons goes over the limit.

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Actually it doesn't work that way. The ppm in 200ppm is parts per million. Even if the number of buttons goes up the parts per million does not. It isn't cumulative. 200 parts per million means that for every million "parts" 200 of them are lead (I have no idea what the measurement for a part is). That amount does not go up just because you add another button. There are still only 200 lead parts in per every million parts. It's a measurement of disbursement, not of total quantity.

[Lavender2Lace]

However, the CPSIA testing which will happen eventually is for the total finished product. Maybe I am confused, but why would they be putting that into the law if they didn't want to see the accumulated amounts of lead and pthalates in the finished product in toto?

If it were merely testing for one item like a button, then that is that. But that is not how the law was written.

I guess that is the crux of the matter and the source of confusion.

I think they have to clear this up. Is it the sum total of all the parts, or the ppm per each part that is the basis for the law.

Apparently they have written it as a sum total situation, and we are all hoping that it is an amount per each part.

[Former_Member]

marking

[Former_Member]

Lavender2Lace, taking an object with a lead content of 200ppm and attaching it to an object that has a lead content of 400ppm does not result in an object with a lead content of 600ppm. It actually drops the total lead content below 400ppm. How much or how little it drops it would depend on the relative size of the two original items. If both things were the same size the new total lead content would be 300ppm. I'm not talking legalese, I am talking math. The number's don't jive that way. The number represents a relative lead to non lead content. As long as no single part of the object has a lead content over 600ppm, the item as a whole cannot have a total lead content of over 600ppm. It's mathematically impossible.

The finished object testing is about the warm fuzzy wuzzy-ness of being able to say "Every product tested, and shown to be lead free!" and not with the possibility of multiple trace lead components adding up to a non trace lead whole.

[Former_Member]

*er, numbers not number's in that first paragraph. Sorry.

[Former_Member]

I would think button is a yes they are included. I understand your frustration and confusion! I'm still not very sure if soap is included!!!

[Former_Member]

The small parts regs have been in existence for a long time. You need to make sure that you include a warning that small parts are a choking hazard - though I have not seen this on children's clothes with buttons. Play it safe and include the warning.