Help with my new items please

[Former_Member]

I used to sell children's clothing and was keeping up with all of this at the time...now I am making children's toys and somehow the thought never crossed my mind until a teammate on another team mentioned it.

I am making children's toys out of felt, and other items such as buttons, ribbon, etc.
My quiet books are connected with metal grommets (eyelets) and then held together with metal binder rings. Some items will have buttons, ribbon, velcro, snaps, metal rings, unbreakable mirror, etc.
My biggest concern is on labeling and small parts.

Can someone please help me with what needs to be labeled with content and care, and what needs to be done for items that are intended for babies?

I have these small books for babies. The only small parts are the grommets (which theoretically could come off, but are not intended to) and the metal rings to hold it together. https://www.etsy.com/listing/160192935/shapes-mini-quiet-book-mini-busy-book?ref=shop_home_feat

Any help is greatly appreciated! I know that it is completely my own fault for overlooking this until now!

[Former_Member]

Ok, I already see that I need to revamp this product.
My plan is to get rid of the grommets (they have not proven to meet standards), and remove the metal ring holding them together. I will instead make button holes, and use either plastic rings (baby toys) or use a well secured ribbon!

Now my main question is, how does the lead testing apply to children that are older? say toddlers or school aged kids?

I will keep reading through everything, but again appreciate any tips!

[Former_Member]

I have found most of my answers through further research. Anyone know where to look to see if my grommets on my quiet books are "functional" therefor exempt from the lead testing?

[FayeMaloneDesigns]

Functional as opposed to decorative? Meaning do they have a purpose or are the just pretty? Since they reinforce the holes that the clips go thru, they are functional. they have a necessary purpose.

[Former_Member]

yes they would be functional....but what does that mean as far as requirements go? From what I have found, the ones that I currently have are "not intended for children"

[FayeMaloneDesigns]

Can you give me the link so I can look at the context of your questioning the use of the wording "functional" as it applies to the grommets? Functional as I know it from the opinions from the CPSC commissioners on buttons, talk about buttons on children's garments are small and do not need to meet the choking guidelines because they need to be small to be functional. But that would refer to buttons used as closures on a garment. Buttons that are simply decorations on the garment may need to meet the choking requirements.

The "not intended for children" you will find on untested supplies that adults may use to make items for children. Children in most circumstances would not be the intended user, as they would not be the one applying the grommet to the widget.

For example, crayola markers would normally be considered children's products, even though an adult could feasibly use them, they need to be tested before sale by the manufacturer. To contrast, art markers by Prang and other manufacturers could be used by children under 13, but, because they are normally marketed and purchsed by adults for their use, they will not be tested. But,if you use the Prang art markers to "paint" something on a child's t-shirt, you will need to have them tested. You have become the manufacturer of the children's product so you have converted the supply from adult to child.

I think I'd skip the grommets and metal rings and go with button holes and ribbons, which would be entirely baby friendly and washable. All testing would be unneeded. problems solved.

[Former_Member]

Thanks for all of that explanation!

I have 2 last concerns:

First would be the grommets and rings holding together my regular size quiet books. These are intended for toddler and up. I will have to get more specific as I read more about the age determinations.
These have not been tested, again, because they are intended for adults to use. In order for me to use them, do I then have to have them tested, or is there an exemption that I may be missing?

Also in regards to the products for the toddler and up ages, if I use a button as a decoration (for example a pigs nose), what has to be done to make that ok? I plan to use only plastic buttons...solid colors. I can't find the materials that they are made out of on the package. Do these have to be tested for lead? And if I understand correctly, it depends on what age they are for, in regards to them being a choking risk?
Again, I haven't finished reading all of the age stuff yet. :/

Thanks again for all your help! It seems like there is so much to go through and it looks much more intimidating when you first look at it! I'm slowly working through everything though. I just feel a little rushed because, by my own mistake, hadn't looked into this until I had orders waiting to be done and listings already up.

[FayeMaloneDesigns]

Amanda, have you registered as a small batch manufacturer?


http://saferproducts.gov/SmallBatchManufacturers/

[Former_Member]

No, but I will do that now!

[Former_Member]

I got a response from them that I need to verify a bunch of stuff because my email address doesn't match my business name.

[FayeMaloneDesigns]

Amanda,

Follow this link and read down to my response and how to for your response to your application.

https://www.etsy.com/teams/6861/keeping-up-with-cpsia/discuss/10115047/page/1

You're almost done.