Crayon wallets

[Former_Member]

If I use only Crayola crayons in my crayon wallets, do I still have to have my crayons tested? And if so, do you think Crayola will send me a copy of their certificate?

I have to say...making stuff for kids is beginning to look like a HUGE undertaking that one should consider carefully before engaging in!

[missymaetutus]

I was wondering this too... I make busy bags that have crayon holders... Thinking to just omit the crayons and don't deal with the hassle! I guess that's the mood I'm in lately:). Use the phrase "crayons not included" lol!

[HookedOnMOeZ]

I'm just thinking, if it's a whole pack of crayons in there like box and all would that take u out of the mix? probably not but just a thought it isn't like u are altering the actual crayon u are just putting it in something... and the bag is really for the adult not the kid lol... yes I'll find u loop holes LOL
j/k, but really kids don't care about the bag... they just want what's in it...it's not like the "use" any of it, unless it's a chalkboard bag or soemthing...

[FayeMaloneDesigns]

Include the crayons in the original Crayola box. The box will aready have the tracking information for the crayons on it. Just label the fabric holder with your tracking information.

[Former_Member]

After doing some more research, I found a FTC publication with information in regards to the material used to make the crayon wallets.

"The following items are not covered by the labeling requirements:...Textiles used in: handbags or luggage, brushes, lampshades, TOYS, feminine hygiene products, adhesive tapes and adhesive sheets, cleaning cloths impregnated with chemicals, or diapers." (I added the capitals)

This makes me think that my crayon wallets are exempt from labeling requirements. (If anyone knows otherwise, let me know, I really would like to be in compliance).

Here's a link to that document:
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21

As for the crayons, you're probably right about including the packaging, but that isn't going to work with the way I currently make and sell my wallets. I usually buy a huge box of crayons and then split them up into groups 8. And, right now anyway, my wallets are made with 8 individual slots for crayons, not one pocket for a box. I'd rather not have to change my design, but if it makes it easier to comply with regulations, it might be worth it.

I sent a question out on the CPSIA site this morning asking about the crayons. I'll let you know what they reply.

[Former_Member]

Here was my direct question to the CPSIA:

"If crayons are included in a children's crayon wallet and are Crayola brand, is any type of testing required? If not, is the wallet manufacturer responsible for any type of documentation?"

Their response only addressed my first question, no help with the second:

"Thanks for contacting us.

Are children’s art materials subject to the new lead limits?

Generally yes. To the extent that such art materials are designed or intended primarily for children 12 years of age or younger, they are subject to the lead limits under the CPSIA. Moreover, all art materials, whether or not intended primarily for children, must comply with the Labeling of Hazardous Art Materials Act (LHAMA) codified at 16 C.F.R. § 1500.14(b)(8), which requires that art materials be properly labeled if they present a chronic adverse health effect."

[FayeMaloneDesigns]

FTC labels are entirely different and seperate from the CPSIA labels. All children's products require CPSIA labeling. No exception. FTC labels are Federal Trade Commission labels with fiber content, country of origin and care instructions. CPSIA are labels required by the CPSC, the Consumer Product Safety Commission, as per the CPSIA law passed in 2008 and that went in to effect in Jan, 2009.

If you just include the entire box of Crayola crayons in it's original box, with your crayon wallets, the box will have the neccessary labeling to cover it's contents. Then you will only have to put a CPSIA label on your crayon wallet. Or don't include the crayons, and sell only the fabric wallets. If your wallet is only made of fabric, then you have no testing requirements as fabric by and large is exempt from testing.

[Former_Member]

Beverly, thanks so much for the information. I've been getting kinda discouraged with how difficult it is wade through all the information and figure out what needs to be tested, what doesn't, and how to make it all work prophitably for my little shop. I appreciate more experienced folks like yourself and your willingness to help.

[HookedOnMOeZ]

I'm not sure where to find them, but restaurants and so forth use those little boxes of crayons... I would think if u contacted crayola directly and asked how to get ahold of boxes of 4-8 crayons that u could include they probably could direct u in how to do so, or wait for halloween and look for a back to use as hallween treats, maybe there would be some out now for easter baskets... just a thought on how to include the box with the info... then u could just place the box with the order and they can insert them into the slots themselves. I know that would be more then fine with me :) that way if they melted in shipping or something they wouldn't be all over the wallet anyways... Maybe even put the crayon in a ziplock bag for any melting issues

[FayeMaloneDesigns]

Small boxes of crayons can be purchased at Walmart.

[Former_Member]

That is a great idea to leave the crayons with the original packaging!