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CPSIA Help

Okay. I've been reading stuff all weekend and all its done is confuse me even more! So I am seeking help to make sure I understand and correct what I misunderstood. I would be a small maufacturer (I meet the criteria for it). And from what I understand, certain items are exempt from certain tests even in childrens products if you're a small manufacturer (textiles, precious gemstones, etc). Items that are inaccessible to children in the final product are also exempt. If a supplier of products has a CPC certificate for a component part, than, as a small batch manufacturer, it is not necessary to test that component as long as you have a copy of the certificate that shows it complies. All childrens items manufactured need a tracking label on there that shows the manufacturer name, place of origin, and identifying features (such as a sequence of numbers). Also, each manufacturer needs to keep a record of where component items come from to keep a record to make compliance easier.

And then I have a couple of questions. As a textile, would ribbon, silk, felt, tulle, elastic, and chiffon count? If yes to ribbon, would it count for ribbon that has been printed on, or ribbon containing glitter or foil on it (I'm thinking the last two won't). If it's okay to use a suppliers CPC to show the componets compliance, will the final product still need to be tested as a whole? Do you have to use a government lab as a small batch manufacturer to test items and is the cost typically per test or per product given? Also, since I make childrens hair accessories putting the tracking info on the product would not be practiceable so is it okay to put the tracking label on the packaging?

Sorry I feel like this is very long, but I know it's important to do this and do this right so I'd rather ask and be safe than not and be sorry.
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Re: CPSIA Help

I would like to know the answer to many of Krissy's questions. I make bows, and use felt, tulle as well as other products which I can now see I need to not use as I do not have proper documentation of. Craft supplies that I have receipts for from Hobby Lobby, but do not have a certificate from for my protection. I see now I need to take a few steps back and reorganize what I'm doing. However, I embroidery and make fealties, so this question is very important. I would think felt is considered a textile, but once I embroidery and cut it out at the end of the day it's still felt, but the size has me concerned.
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Re: CPSIA Help

Your first paragraph is a pretty good understanding of what you need to do.

As for ribbon, tulle, chiffon, and elastic yes those are all textiles. Ribbon that has been printed on may need testing for lead in paint. If the design can be scraped off or cracks and peels, then the printing has not become part of the substrate, testing would be needed or if you are registered a testing certificate from the supplier could be used to cover you. Glitter, if it comes off I wouldn't use for children. Metallic can't be metal, it has to be a metallic looking film. Get a testing certificate to cover yourself. Metal wired ribbon don't use. fishing line in the edge would be okay.

Yes, you would have to use only a government approved lab for any testing, and the test charge is per test. If a product falls under 3 tests like lead in paint, small parts and use and abuse., you would be charged for all three tests. Also. The testing destroys the item. Generally if you have to send off for testing they want 3-6 identical products for testing.

If the product is too small for an actual label, then you would put the information on a card that the product was attached too. Think of hair bows and jewelry you find in the department stores they are on a card with holes punched for hanging and for the product to be displayed. Jewelry and hair bows are the exceptions to permanent labeling.
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Re: CPSIA Help

How are the felties used? In hair bows as a decoration? on garments? as a play items?

Most textiles are exempt from testing, and yes, tulle, felt and threads are textiles. If you use wool felt you need to use wool mark labels as per the FTC even though hair bows do not normally need FTC labeling. Hats do though need regular FTC labeling and wool tags If you use wool in anything you have to have wool FTC labels

You need to register as a small batch manufacturer to use suppliers testing certificates on those non exempt supplies.
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