Former_Member
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CPSC Compliant Baby Blankets

Hi!

I make custom embroidered baby blankets made with 100% cotton on one side & minky dot (100% polyester) material on the other. I've been looking into all the CPSC requirements and it seems that I do not need to test for lead, and the fabrics already meet flammability standards by weight or fiber content. It started out as only a hobby so in my initial research I made sure my materials were compliant with the standards, but I didn't realize the requirements on labeling. I don't have a real business/company going for this, it's only me and still only a hobby right now, but I'm looking at expanding.

I've been researching for quite awhile but it's all very wordy and I want to make sure I'm understanding correctly. Here are my questions:
1. I realize now that I need a FTC Tag stating my name, the year made, fabric type, country of origin, and that it was made in USA. Anything I'm missing?
2. If my materials are exempt on lead testing, and meet the flammability standards by weight or fiber content, are my blankets compliant? Do I have to go through anything to state that these blankets are compliant or can I make my own document stating this with the research I have backing it up?
3. Am I missing anything else regarding compliance and selling these baby blankets?

Any and all help is appreciated!! I'm starting to get a lot of interested people, but currently put it on hold until I have more answers.

Thanks so much in advance!! :)
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Re: CPSC Compliant Baby Blankets

If you intend to sell or donate your blankets, you are not just a hobbyist, you are what the government considers a small batch manufacturer. You may only be on Etsy, but you are a manufacturer of consumer products. and if they are for children, a manufacturer of children's products and all the rules and regulations apply. You should apply for a Small Batch Manufacturer exemption, it's free, and painless, and is good for one year only and has to be reapplied for each year as its based on your sales from the previous year.

1. There are 2 types of labeling you will need to comply with. 1, the FTC ( the Federal Trade Commission) labeling for country of origin of the fiber content for bedding and 2. the CPSIA ( the Consumer Product Testing Commission safety law called the Consumer Product Safety Information Act) tracking labeling. You may combine the information onto one tag if you choose, but all the information must be there. The CPSIA tracking label must have Your company name, (you may use your Etsy store name URL or your company's separate web site URL), the city, state, country where you are located. The customer has to be able to find you if they need to get in contact with you. And the date of manufacture. The year is not sufficient, month or season would be the minimum. There need to be sewn in as they are permanent labels.

2. Your blankets won't need 3rd party testing as you have described them, but you will need to make a Certificate of Compliance for your files. You will need to list every regulation you need to comply with and how you have complied. The sample to follow is shown in the pinned thread at the top of the discussions under the CPSC ombudsman's thread. You have to just find the link to the sample certificate of compliance. These aren't given to the retail customers, (like your Etsy customers), but are for the government if they need to see your compliance. You are basically certifying that your products are safe, and the reasons that they are.

3. Other than that you appear to be okay. Do remember if you change or add additional items to sell, you will need to make a new Certificate of Compliance for the other items and may need different labeling.
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Former_Member
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Re: CPSC Compliant Baby Blankets

Thanks so much, Beverly! This is a huge help!!

Am I required to register as a small batch manufacturer even if my products are exempt from testing? And if so, what's the reason behind this (out of curiosity)?

Thanks!!
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Re: CPSC Compliant Baby Blankets

No, you are not required. But by not registering, you limit yourself to what you can make and sell. And technically, you should have your fabrics tested by a government registered third party lab for flammability. Your flammability testing exemption is based on the small batch exemptions. You can't use a button, or snap, or decide you want to make clothing. You really, in the governments eyes, must follow all the requirements of Walmart, Target and JCPenny. It took a 3 year fight and a lot of man hours and lost small businesses to get the small batch manufacturer exemptions so that all of the hobbyists and SAHMs and Dads that the government didn't even know existed to have those exemptions. If we don't register and the numbers drop too low, and the winds change in DC, we could find that there could be no more small batch manufacturers in their eyes. We'd all be in trouble.
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Former_Member
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Re: CPSC Compliant Baby Blankets

I totally understand! Thanks, Beverly!
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