Former_Member
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CPSIA

I want to know about this, too! Specifically, buttons. I haven't even started making everything yet because I'm still trying to figure out which supplies to buy.
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Former_Member
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Re: CPSIA

If all my materials are CPSIA certified, then is the assembled product ok to go? Do I still need testing on the finished item? Would I have to just provide proof of safety from all the sources? Any help would be great... I'm just starting out :)
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Re: CPSIA

themotrb says:
If all my materials are CPSIA certified, then is the assembled product ok to go? Do I still need testing on the finished item? Would I have to just provide proof of safety from all the sources? Any help would be great... I'm just starting out :)
*****

What do you mean by CPSIA certified? CPSIA doesn't certify anything. After looking at your store (what a great idea you have!) you say you are using ripstop, fleece velcro and elastic and thread (I assume). All of those items are exempt from testing. So, all you need are CPSIA labels, and perhaps FTC labels.
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Former_Member
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Re: CPSIA

You may want to see if you can get help from your local artist guild, SCORE mentor, or the regional SBA office in obtaining professional legal advice about making and selling specific products due to the complexities of the CPSC, CPSIA, state based laws, and the FTC (a second federal agency that has regulations about consumer products in general). Especially since some of the laws and regulations may effect similar products in different ways depending on what they are made from, which age group they are made to be used by, or how they are advertised.

Since there is no such thing as CPSIA certified, only CPSIA compliant, you need to have proof of either the exempt status or what the lead level is of all the components are that are used in the completion of the product you are selling. See http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf for a list of lead testing exempt materials, even when using all lead testing exempt material personally I would keep whatever packing describes the components to prove what I bought fits the descriptions on the exemption list. For non-exempt items see if you can get a hardcopy of a GCC, COC, or actual test results from the component manufacturer & make sure that the lead is reported in PPM not just pass/fail & the test used matches what the CPSIA has pre-approved as allowable. That should satisfy the component testing criteria outlined here http://www.cpsc.gov/cpscpub/prerel/prhtml10/10083.html . If the manufacturer's testing or reports don't match what's needed by the CPSIA then you may need to have the lead testing done privately at your expense, and having components tested prior to assembly makes it easier to do OOAK and special order items. Remember the permanant tracking label / tag also must be made of tested or exempt materials since the government considers that to be part of the finished product. Read more about tracking info that is required on every product for children under 13 here
http://www.cpsc.gov/about/cpsia/sect103policy.pdf .

Beyond the lead testing there may be other tests that are specific to the product type or the age group that the product is meant to be used by, on or for. Phthalate testing is required on all toys and games for children under 13, and on any product the government considers child care aid, feeding aids, or slepping aids for children under 4. Small parts testing is required for most items that are descibed as being usable by children under 7, and if an item fails that testing it must carry a warning that it is not be used by children under 4. Additionally there are product specific laws and regulation, like flame resistancy ratings for sleep & lounge wear, entrapment assessments for opening on hard and soft baby carriers, minimum / maximum height & thickness for crib, cradle, and bassinet bumpers, allowable lengths for drawstrings on pants and hats, and many, many more.
Gateway for links about phthalate requirements
http://www.cpsc.gov/about/cpsia/sect108.html
Small Parts Regulations Summary http://www.cpsc.gov/BUSINFO/regsumsmallparts.pdf
Small Parts labeling
http://www.cpsc.gov/BUSINFO/label.pdf
and how they should appear in your listings / ads
http://www.cpsc.gov/LIBRARY/FOIA/FOIA08/brief/toygameads.pdf page 19 of the PDF has the abbreviations & page 20 of the PDF has the warning examples are in black-n-white which is I believe OK for a listing but they need to be in certain colors on the actual label for the physical product or packaging.
The main CPSC website to search for product specific laws & regulations
http://www.cpsc.gov/
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Former_Member
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Re: CPSIA

Thanks so much for replying! I now have some great resources. I apologize for taking so long to thank you, but my daughter had me whisked away to L.A. 3 times this month!
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Re: CPSIA

Marking
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