Double check me on compliance?

[Former_Member]

Like many others, my brain starts spinning whenever I investigate CPSIA stuff, but I couldn't put it off forever. I wanted to get my children's slippers back in my shop, and need to ensure my compliance for a craft show that is coming up. Even after deciding that I was a-okay on compliance (because my slippers are 100% wool), the issue of non-slip soles for the slippers has come up several times with my customers, so I decided I really must find a compliant way to address that problem.

I'd appreciate your feedback on my current thoughts, which are that I can indeed sell kid-sized slippers, and that I can use "puffy paint" as a tread material:

1. The slippers are made of 100% wool yarn, a material exempt from lead testing. The felting process doesn't add lead to the equation.

2. The slippers, as footwear, are not "toys" or "child care items" and therefore the slippers would also be exempt from testing for phthalates. (per CPSIA FAQ: "Shoes and socks are not considered to be children’s toys or child care articles" and only toys and child care items are requiring phthalate testing.)

3. I were to offer a "non-slip" feature for my slippers using commonly available "puffy paint" (which is tested lead-free, but not necessarily phthalate-free based on what I can tell), I still wouldn't have to undergo phthalate testing, right now, because they aren't a toy or a child-care item, but in the realm of shoes and socks.

4. As long as I label my slippers per the guidelines, and have a website address on there that can serve as a method of contacting me, I would be in compliance today.

Do you agree, and if not can you help me find any faulty logic or misunderstandings on my part?

Also, I'd like to add that I currently don't make slippers for "learning walkers" age groups--so the slippers with treads wouldn't be intended for children who are still mouthing things--and while I am planning on adding baby booties to my inventory, I won't be putting treads on those.

Thanks in advice for any feedback!

[Former_Member]

"A children’s product is one designed or intended primarily for children 12 years of age or younger. Toys, clothes, furniture, books, jewelry, blankets, games, CDs/DVDs, strollers, and footwear may all be considered children’s products" page 4 of the CPSIA Small Business Guide http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf

It's my understanding from the above quote that footwear is included. I would think that you need the GCC from the paint company that it is in compliance. But you would do best to contact the CPSIA directly, as it's confusing to everyone!!

[Former_Member]

Thank you 2sweetthings, children's sizes will definitely be considered children's products, but the statement I had in there was that they are not toys and are not child-care related items, so they would be exempt from the phthalate testing according to the CPSIA guide (but not the lead testing and labeling requirements).

Regarding GCCs, I've seen lists of companies supposedly CPSIA compliant, but are they really providing GCCs when requested? Also, I've read that "component testing" isn't a sure thing, so is having a paint manufacturer's GCC going to protect someone from the testing requirements when the "stay" is over? I'll keep searching for the answers and look forward to more feedback!

[Former_Member]

I think for now (until 2/2010) the GCCs/component testing are what we are going on. I have received GCCs from several companies whose products I use (velcro and buttons). What will be fine after February is anyone's guess at this point!

[Former_Member]

Well, and here's another thing--I've always preferred to not to put anything on the soles at all, so if you have opinions about whether it is advisable to continue selling these slippers with naked soles please share!

[Former_Member]

2sweetthings, that you gotten some GCCs from suppliers gives me some hope. I've got emails out in the hopes of finding a company that will provide them, but was worried because the word I've heard is that many manufacturer's aren't feeling like it is their responsibility. I've decided that I'll bend over backwards to utilize materials from companies that are willing to step up to the plate for us by getting their GCCs in order.

I've thought that I might even pay the cost for testing if it came down to it (and component testing is possible), just to have the peace of mind that I'm doing all I can to be certain. I feel between a rock and a hard place regarding the non-slip soles issue--it's pushing me closer toward just dropping children's sizes altogether. I'd always thought I'd use suede for soles if it came down to it, only to run into the "there's no such thing as 'untreated leather'" issue.

[Former_Member]

Unfortunately any type of paint must be tesed by the 3rd party as of NOV 2008, regardless of it it already carries any other form of certification like an ASTM #, GCC, or COC.
Paint & pigments of all kinds are not included in the stay of testing. Like jewlery, cribs, & certain other newborn to toddler products there is no stay for anyone producing these products. See Table A at http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q4 .

I don't know much about how to make booties or slippers, but is there another fabric related product that could be used like a fusing or interfacing that could be for the no-slip bottoms. Many of these items are either exempt or the manufacturers are will to give usable GCCs.

[Former_Member]

Ah, I see, thank you jewelrydesignsbyME for pointing that out, I thought I'd found a loop hole, but obviously not. So the slippers will need to be naked until I decide to pay for testing. Thanks for the suggestions, I've looked into non-slip fabric, but it really comes down to aesthetics for me.