? CPSIA and art prints

[111collagedesign]

Hi. I was thinking about trying to market some of my giclee prints for children's rooms etc.

Given what I have learned about CPSIA, I am not sure if this type of product is exempt or not. I would still be marketing to adults too, just expanding my market to include children.

I get my prints from Iprintfromhome.

Any info would be appreciated Thanks

Abby

[knitwit4ever]

The rules for products marketed for children can be confusing. My understanding as it relates to your prints:

If the item is marketed primarily for children and will be used by/interacted with by children it must be compliant. The example I have seen is a growth chart, mounted at child height and touched by the child when used.

Decorative artwork that is used in a child's room but is not for play, mounted above normal child-reach height and is viewed but not interacted with by the child does not have to be compliant.

[111collagedesign]

thanks - that is very helpful.

[Former_Member]

I'm not sure but the Giclée process may fall under the broader part of the CPSIA which concerns lead in paints and surface coating for all general consumer products as well. You may want to see if you can get help from your local SCORE mentor or the SBA office in obtaining legal advice about such products.

If the products do fall under the broader scope of the CPSIA you will need lead testing information or letters about using lead testing exempt materials from the printing house. There could be a difference in how the law effects your business depending if you market it as general use or primarily for use by some one under 13. For general use all you need is to keep a file with the test or exempt status information for each batch of prints made. For prints that will be marketed with children under 13 in mind you will need a GCC that you keep with the testing or exempt status info and permanant tracking information on the product itself.

[Former_Member]

knitwit4ever says:
Decorative artwork that is used in a child's room but is not for play, mounted above normal child-reach height and is viewed but not interacted with by the child does not have to be compliant.
........

So far we're unable to find a definitive answer, but where I work, we test this type of product to be compliant. Normal child-height reach for a 12 year old is the same for most adults. Unless you specify that your art can only be hung flat on the ceiling, it's hard to get around that. :-)

[111collagedesign]

Oh boy, this is complicated. I guess I can contact where I get my prints made (Iprintfromhome.com) and see if they know anything about this issue...

I am not even really planning to market to children primarily, just thinking about adding a few tags (e.g. kids room)in my etsy shop since I think some of my art prints would be nice for kids as well as adults.

I'm not making any money from my art at this point, so I'm not going to spend a whole lot of time getting things tested etc..I'd just continue marketing only to adults as I have been

[knitwit4ever]

amyblandford, this particular issue was discussed during the Virtual Lab session with the CPSIA representative last spring. It sounded like the common-sense approach was being used: perhaps a child could reach the item but if there was no play-function involved and it wasn't where a little one would be licking/touching, then fingers into mouth/interacting with the decorative item except visually, they didn't consider it necessary to be compliant.

[Former_Member]

knitwit4ever says:
amyblandford, this particular issue was discussed during the Virtual Lab session with the CPSIA representative last spring. It sounded like the common-sense approach was being used: perhaps a child could reach the item but if there was no play-function involved and it wasn't where a little one would be licking/touching, then fingers into mouth/interacting with the decorative item except visually, they didn't consider it necessary to be compliant.
..............

Good to know, I wasn't part of that meeting.
At work, unfortunately we've been given the opposite advice regarding screen-printed canvas wall art and photo frames and such. There's no play function in a frame either, but apparently it can still be considered child-appealing. At first we added a "not a toy" warning sticker, but have been advised by our Quality Assurance dept. to test for lead in surface coating, lead in substrate, phthalates, sharp edges, and depending on the material, flammability.

BUT- they've also decided we must meet the requirements for H.R. 4428 (Heavy Metal-Cadmium, Barium, Antimony in Children Jewelry) and that bill hasn't even been voted on and may never make it out of committee. We're betting that it will, I guess! point being- the advice we're getting may be overly cautious. But we're still following it. Whether people here should too, I honestly can't say!

[knitwit4ever]

amy, you've hit the nail right on the head! "the advice we're getting may be overly cautious. But we're still following it. Whether people here should too, I honestly can't say!"

This law has changed and evolved with rule changes and interpretations. I'm not even sure you'd get the same response from two reps from the CPSIA--or from the same one at two different times. We're all just doing the best we can to understand and stay in compliance!

I believe it is really unfair when citizens TRYING to obey the law have this much difficulty figuring out what the rules are...

[AyalaArt]

I dont think if is not meant to be a toy, or be worn, to be touched, it would have to be tested. I would ask the company to see what they use just to have the info.

oh, I went to see Iprintfromhome, and they have a link to my ACEO guide!! hehehe that was a surprise!

[Former_Member]

Someone convoed me for more info about the bill I mentioned (H.R. 4428) that would require testing for cadmium & other heavy metals, so I thought I'd post a link here in case anyone else is curious.

This is NOT a law yet, and might never be. It looks like it would specifically cover children's jewelry and not other children's items.

http://www.govtrack.us/congress/bill.xpd?bill=h111-4428

[FayeMaloneDesigns]

perhaps a child could reach the item but if there was no play-function involved and it wasn't where a little one would be licking/touching, then fingers into mouth/interacting with the decorative item except visually, they didn't consider it necessary to be compliant.

Okay, wouldn't this apply to a zipper in the back of a little girls dress, or even the buttons down the back. Mommy would be buttoning, zipping, it's not a play thing and the little girl would have to stand on her head and be a contortionist to button up the back of her dress if she could even accomplish this. Again another reason I would like to zip up in an unzippable sleepingbag and drop into a vat of home made untested silly putty the idiots that passed this law.

[Former_Member]

This is soooo tricky. I know the holiday season is going to bring a lot more questions about things that appeal to kids but are for decorative purposes. But with the art prints, might they be considered to be inaccessible if they were framed? I realize the framing materials would have to be compliant, but maybe that would be easier to get paperwork on then inks and paint. Maybe you could put a warning stating that it could only be used for a child's room if it were to be framed?