CPSIA Information from my Supplier

[Former_Member]

Obviously, it is important to speak to a lawyer to answer any questions you have about your particular business. But, I just spoke to my supplier (they create thick onesies for small embroidery businesses). I simply embroider the onesie with a name or saying and add ribbon. He assured me that I would not be considered a "manufacturer." That as long as I have a certificate from all my suppliers that my product would be considered compliant. He also said, it is not something that we have to have unless the item was MANUFACTURED after Feb 10, 2009. So we do not need the certificates until we are actually purchasing supplies that have been manufactured after Feb 10th. He said that all other items are "grandfathered" in. He stated that manufactures will have to worry about these regulations and that I will just need my certificates given to me by the suppliers.

I really wish we could receive further clarification about all this. Does anyone else know anything that conflicts with this information?

[TheTinyFig]

From what I've read, if you make the end product YOU are the manufacture. Also, I'd like to see you find a supplier that would be willing to give you one of those certificates. It's impossible for them to provide all of their customers with those certificates and even if you get them there's no guarantee that will be enough.

[Former_Member]

I'm not trying to be a downer, but I would like to see his source for this information. I'm not sure it's accurate.

[Former_Member]

Everything I have read says the law is retro active. You will have to prove it's lead free even if it was made before the 10th.

[Former_Member]

where I can find more info about it? Some link?
My good friend wants to start selling wonderful thing for children....

[Former_Member]

So about the testing, do you have to test just your supplies or every single different end product?

[Former_Member]

that's what i would say if i were a supplier. he's going to be out a lot of business come feb.

[Former_Member]

yes you would be, because you are adding to the original product with more materials

[Former_Member]

You are both manufacturer and retailer. Both manufactuer and retailer need to have the certificates available for inspection.

CPSIA is also RETROACTIVE. You must produce the certificate for anything produced before that date too!

I own a retail store and am looking at having to destroy about 10% of all my books come February 10th due to the retroactive part.

Your supplier is misinformed.

[Former_Member]

I think he's been misinformed.

[Former_Member]

I understand it's the end product, which is why this is such a huge deal. I don't see where it says anything before Feb 10 is exempt, so I'd say it's not. Sure would like to know where he is reading that at.

[Former_Member]

<<thatssobaby
So about the testing, do you have to test just your supplies or every single different end product?>>

Every product line. Even if made with all the same materials, on same day, with same tools, you must test two products separately. it must be done by a third party lab.

[Former_Member]

If you make the product your are the maunfacturer. If you sell the product you are retailer. We are both. Items produced before the 10 have to be tested. The big hoopla over resale shops and little toy stores and boutiques. Certificates at this point are not accepted.

[Former_Member]

That information is very different form every source I have read, including the law itself. What authority did the man use as a source for his opinions?

It sounds like he told you what he THOUGHT would make sense, but the law doesn't actually make mushg sense at all. At this point componant testing (supplier testing) is not an option. That may change before Feb 10th I suppose, but at this point it's not enough.

The CSPC defines a manufacturer as anyone who makes a product. So yes, you are the manufacturer, unfortunately.

thatssobaby says:
He also said, it is not something that we have to have unless the item was MANUFACTURED after Feb 10, 2009. So we do not need the certificates until we are actually purchasing supplies that have been manufactured after Feb 10th. He said that all other items are "grandfathered" in.

This also is not true. Would make snese and save a lot of people a lot of heartache, but it is not how the law is written. All items need certificates of compliance after Feb 10, regardless of manufacture date.

[Former_Member]

Hi Everybody,

Could you all please write a letter about this CPSIA law to www.oprah.com

She has place where if you want to be on the show.......

And there is a question about what are your concerns in the news.....

This would be worth a try.... Maybe Oprah with her media advantage could change things for us.

Wishing you all the best.

Caroline Riepler

[Former_Member]

She does have a special relationship with Obama....