Do you still need tags if...

[Former_Member]

your amigurumi is meant to be just for display? Would you called them fabric or fiber sculptures and say they are not for children under 13? I'm new to all this CPSIA stuff. I was very shocked to see this so I'm glad I didn't put any up yet. I usually use cotton or acrylic yarn, polyester stuffing, safety eyes and every now and then little plastic decorative buttons...

Thank you for reading.

[ByNanasHands]

If they would appeal to children under 13 years of age I would think you'd have to be compliant with the new CPSIA rulings. Which would mean you'd have to have them tested because of the eyes and buttons. Leave those off, label them correctly and you should be ok as yarn is exempt as well as the polyfil stuffing (if it's new and not "recycled").

[Former_Member]

Unfortunately since amigurumi is defined as being a crocheted or knitted stuffed doll it must follow all the rules of the CPSIA even if you mark as display only. It still falls within the governments definition of a doll or plush toy, see the CPSC's age determination guideline http://www.cpsc.gov/BUSINFO/adg.pdf . Unless you make the doll in some sort or exetreme artistic design (such as made of crocheted wire) or as a high priced collectable (such as using vintage items to embellish it) I don't think the government will buy the description of a fabric sculptures as a form of excluding your product from testing and labeling.

Remember you will need on any non-exempt raw material at least lead testing. For most toys a use and abuse testing is also needed if marketed to kids 3 and under - a choking hazard testing on any small detachable portions of the design including and part that breaks off during the use and abuse test. If the item is being sold to those over 3 but under 7 a small parts warning label maybe required once the use and abuse testing is passed. The warning label would be in addition to the required permanant label for the CPSIA and the care & content label required by the FTC.
CPSIA Tracking labels
http://www.cpsc.gov/about/cpsia/sect103policy.pdf & CPSIA's FAQ page
http://www.cpsc.gov/about/cpsia/sect103.html#103q8
FTC Labeling requirements
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
Examples of FTC labels (about 3/4 of the way down the page)
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm
Here's info about small parts warnings
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 examples in black-n-white but I believe they need to be in certain colors on the actual label.

[LeafandYard]

From the Guide to the Consumer Product Safety Improvement Act (CPSIA) for Small Buisniesses, Resellers, Crafters and Charities, http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf , it states,

"In determining whether a consumer product is “intended primarily” for a child 12 years of age or younger, the following factors will be considered:
• A statement by the manufacturer about the intended use of the product, including a label on the product, if such statement is reasonable.
• Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children 12 years of age or younger.
• Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
• The Age Determination Guidelines issued by Commission staff.
If a product is intended for adults or for general use by consumers of all ages, then it is not intended primarily for children. Products marketed and priced in a manner that would not make them appropriate for use by a child would also not be intended primarily for children. An example would be an expensive telescope ‐‐ because it is sold for general use by all ages, it is not a children’s product even though it can be used by a child on occasion."


So, if my amigurumi include a statement from me that they are not intended for children, I do not promote or advertise them as toys, and they are intended for adult collectors (which might be "used by a child on occasion" but are not made with that purpose", why would it still be considered a child's product? If the manufacturers intent is irrelevant, then it should not be mentioned as a consideration at all.

This is the part of the law that I don't understand. I don't make children's products. I never have, I never plan to. But, I'm supposed to treat my items like they are just because someone else says they're for kids (when the person who makes them says they are not)? That makes no sense to me.

[TheFairiesNest]

I agree Fryecreek!

[FayeMaloneDesigns]

The problem I see is that in a quick glance at the 1st 3 pages of amigurumi listings the majority of them refer to children, kids, toys, dolls. All key words in determining if it is a children's product. So you can call it what you will, it may not fly by CPSC

[Former_Member]

marking

[Former_Member]

My amigurumi pieces are definately not marketed towards children, yet I make them compliant regardless.

Most of the people who purhchase my amigurumi pieces are collectors.

[Former_Member]

Why do so many sellers seem to be avoiding labels? Is it the tracking - DOM - that is causing the problem? Because it just makes good business sense, at least to me, to label everything with permanent labels in case your customer decides in a few months that they want more of your items - they can find your shop if you label your items!

[LeafandYard]

Actually, I'm not avoiding labels (thought I know I posted on a label-specific topic), I'm waiting for payday so I can buy supplies to make them. I have no idea how I'm going to get them onto a little crocheted sculpture, though. And, DOM is throwing me as well. I'm not going to be able to print out a page of labels and know the exact date that I finish something. Still working on what I can do about that.

However, the poly beads that I put in my items for weight and the safety eyes that I use are not exempt from testing. So, to me, it's a good thing that I don't make children's items because all of my supplies are not compliant. However, once I figure out the label thing (and I still have no idea how it's going to work) I plan on making a child's Gnome - no poly beads and yarn knots for eyes, all exempt-from-testing materials. (Unless I'm mistaken in my understanding that these currently exempt items will stay that way when the big law goes into full effect. Then I'll scratch that idea too and stick with selling Gnomes for young-at-heart working folks like me.)

[bobbinalong]

When I make my baby booties, Fyrecreek, I use a paper label and mark the date I made them as I go. It would be impossible to put a permanent label on one of my booties.

I feel that the people making and carrying out this law really don't realize how what they are putting into print corresponds to an actual item. It took manufacturers to open their eyes to simple things like pencils. I saw somewhere where they were talking about the testing process and how they would put my item - one of my ragdolls - in a machine and add pressure to see at what level the legs would come off. Well, even if I could afford to have one tested, why would I sit here and create this item for that kind of testing. They have gotten handmade art confused with toy manufacturers.

I also saw somewhere in that draft we are waiting on that possibly they would extend the age upward for testing and regulations. It will only be a matter of time, until they will clamp down on everything handmade.

[LeafandYard]

Do you mean that you do your labels like a hang tag instead of affixed to the product? I was thinking of sticky labels that I can affix to a Gnome bum that can be easily removed upon purchase.

I certainly agree that I would be horrified to make a Gnome just to sacrifice it to the crazy people who want to destroy it to see how tough it is and what it's made of. He that breaks a thing to find out what it is has left the path of logic.

Unfortunately, in the land of "by the people," there are far more people who agree with this law than who see it for the problems it causes.

[Former_Member]

Fyrecreek, unfortunately the tracking label must be permanantly affix to the extent that is practical for the type of product. If the product is to small or the label would interfer with the product's operations then the tracking label maybe on the products pagkaging. So for bobbinalong's booties or my jewelry we could be allowed to put the tracking info on the package, at least till some government official disagrees. I don't know how big your Gnomes are but if they are big enough then the label must be sewn to the product.
Also the government and the general population at large get 1/2 of the vote as to if your products are for kids or for adults so a big part of this law is very damaging to grey area crafters like jewelry designers, art doll makers, amigurumi crocheters, accessory designers, print makers, etc. all because what the creator of the item may see as an adult item doesn't mean everyone else that could report an item to the CPSIA would. Personally if I was seaching for a Gnome and came across your listings I would think, at least until I read the complete description, that yours would be appropriate for a child and we all know how often everyone reads the full listing.
As for the shear numbers of people that agree this law they only know the basics of or have mis-information like thinking that it strictly for plastic and painted toys. As for those that how been vocal enough to get this law passed many of them have been supporters of watchdog groups that may of never picked up as much as a needle to sew a button back on a shirt but were disgusted with all of the recalls of toys in 2007. What needs to be done and be done soon is for all the persons that this law unjustly & adversely affects is to be just as vocal as the ones who pushed to have this flawed law passes. Honestly the law affects so many and they do not realize it but they will once someone that's malicious enough reports them & they wind up under investigation. BTW the reporting is going to be public on a website for all the world to see so even if a crafter does prove that their products are for adults the damage could be done to their reputations. PS There is a rumor that goes around every so often that the reporting party will get a share of any fines levied by the government, and if that's true with the way the ecomony is I could see a lot of formerly non-malicious persons being reporting items just for the hope of financial gain.

[LeafandYard]

Guess that means people should buy Gnomes now, because I'll be closing.

[honeybee69]

I finally got my tags made. When finished they are just over a half inch tall and 3/4 of an inch long. I have a picture of my pea pods on there, name of my store, web address, where manufactured, and DOM on one side, and washing instructions and materials on the other. I fold mine in half and sew them in a seam. Or for crochet I hand sew them on. I just made baby booties and put the tags on the inside, came out pretty cute if I do say so myself But now they are done and ready to use.