The first thing you need to do is search the government sites for the CPSC and the FTC to see if there are any regulations regarding hairclips in general. Actually these two sites should always be consulted prior to the start of selling any items that do not fall into cosmetic, bath, or medical products (check the FDA site about regulations for those types of items). Also check your own state's product regulation laws to see if there are any manufacturing standards that need to be followed due to your location. For additional help consult your local SCORE or SBA offices.
The CPSC main pages
http://www.cpsc.govFTC main pages
http://www.ftc.gov Then if you choose to market or describe the hairclips as being appropriate for children under 13, read the government sites about the CPSIA.
The CPSIA main pages
http://www.cpsc.gov/about/cpsia/cpsia.htmlIf after reading the basics about the CPSIA you decide to not market your items as being appropriate for children look at similar products on national retailer's selves by reputable manufacturers for disclaimers &/or warnings to clarify that your products are primarily for adults otherwise consult a law professinal for advice.
If you decide to use tags like girl, boy, tween, child, baby, or infant; or if your description in you listing that the product could lead a reasonable adult to believe the product used by more children under 13 then adults you need to follow the CPSIA.
The law includes having to get:
* testing information concerning the lead content of either the finished product or each non-exempt component by weight
* keeping records of the testing certs or proof of exemption for the components tied to each product
* writing a self issued issued GCC for each product
* include permanant tracking labels with the item and a copy of the same info on the packaging (unless the item is too small then the tracking info can appear on the packaging only)
if needed for a specific types of products or specific ages marketed to:
- phthalate testing results also kept in the records for each product
- testing & warning labels about small parts or choking hazards
It's a lot to take in but it is a federal law, so here are some sites that should help clear things up.
For the current full list of raw materials offically exempt from CPSIA lead testing please read
http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdfAn update on the stay of 3rd party & component testing
http://www.cpsc.gov/cpscpub/prerel/prhtml10/10083.htmlTracking labels required on every product for children under 13
http://www.cpsc.gov/about/cpsia/sect103policy.pdfA general overview from the CPSIA for Small Bussinesses
http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.htmlA gateway page for summeries of the law by subsection
http://www.cpsc.gov/about/cpsia/legislation.html#summariesSmall 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.
