Do I Understand This Right?

[AllThingsBelle]

Okay I sell crochet/knit items for babies/children.

It's my understanding that as of today (June, 2009), that I do NOT have to test yarn, but as of (August, 2009) I will have to have the permanent tracking labels.

Do I have that right? I've read through all the CPSIA and I think I understand, but then I read through the forums and start wondering if I missed something..

Thanks!

[LaurieRyan]

I've not a clue maybe someone else will. I wish the stupid law would go away to keep life simple for you sellers

[Former_Member]

Yes, you are right:(

[Former_Member]

Your right, in my opinion, but Do make sure you can get GCCs or COCs from your raw material manufactures. Remember 3rd party testing is required come Feb 10th 2010, and the testing is retro-active for products in stock unless made entirely of exempt materials, so don't go creating a stockpile of items that won't sell before then.

Testing is required right now for certain items like a painted wooden button, regardless if the entire rest of the item is made from exempt materials, and the supplier certificates will not cut for those "test now" components. See Table A: Compliance and Testing Timetable at http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q5
for testing deadlines.

[MamaFamilias]

"* Testing and certification are not required for products already in inventory that are covered by the new lead and phthalate limits and toy standards. "

This footnote on the timetable would seem to indicate that it is *not* retroactive.

Since my plan is to stockpile, if you can remember where you came across a statement to the contrary, please link to it. Thanks

[SoapsSalvesSundries]

I'm not understanding how I can comply with this part of the law. Many of my items don't have room for tracking labels, and it's going to be difficult to track the number of original items that I make. How do you all plan to keep track?

[Former_Member]

I am in the same boat, classics. I use paint made for glass, & I mix and mix until I get the exact color I want. So does this mean I have to keep up with every bottle of paint I use on a product? I am very confused & wondering how I can do this.

[Former_Member]

Unfortunately the CPSIA has change the page layout of their site. There used to be a section labeled General Counsel Opinions from the law and regulations interpetation team at the CPSC that went over in plain language about the legal rulings that had come out of various State's Superior Courts on rulings concerning the CPSIA, including that at that items already on retail selves must meet the most current lead and phthalate levels with certification regardless of date manufactured. Of course this refers to GCCs & COCs right now, but for the future lower limits does your GCCs or COCs show exact lead and phthalate content in ppm to prove your in compliance when the new levels take affect.
Please read this very abbreviated replacement Section 213. Prohibition on Stockpiling Under Other Commission-Enforced Statutes at http://www.cpsc.gov/about/cpsia/sect213.html .

[MamaFamilias]

Thanks for the stockpiling link. So much for that loop hole.