How to state that I am compliant

[Superflykidz]

I have tested my items and am lead free - how am I supposed to state this in my shop? Do I need to mention it or just be able to provide the information if asked? Just curious.

[Former_Member]

I don't *think* you need to mention it, but I am curious as to what others are doing.
I'm compliant as well, tested everything.

*high fives superflykidz*

[Superflykidz]

Hey there allthenumbers - I feel so much better just getting it over with and not having to worry if I'm exempt or not, but I wasn't sure if it's something I needed to state in my shop announcement or not....

[Former_Member]

Anyone else put an announcement in their store about compliance?

[Former_Member]

I have a blurb about the upcoming deadline in my shop announcement, and information about the different textile companies' testing and their testimony to the CPSC stating that yarn does not contain lead. As far as official compliance with CPSIA goes I figure it's 99.9% sure that textiles will be exempt from testing by the time the stay is over. Sanity and common sense will prevail, we just have to give it time.

I had a call from a friend of mine today, I sent her some info and links about CPSIA recently and the link to my shop too. She said I had beautiful stuff and couldn't believe I've only had two sales since I've had my shop open!

[Former_Member]

I'm torn as to what I'm going to do. Right now, the phthalates issues are weighing me down, blankets and bibs being verboten, apparently, without uber-expensive testing. (I'm feeling a bit German tonight.)

I'll be pulling everything from my stores here and on eBay by Monday p.m. and will have to come up with something about why. It's tough to write, because I don't want any of my customers to think that anything I've sold in the past is unsafe... :/

[Dannielle]

I had a little blurb mentioning it as the reason for the slight price increase. But then I removed it because it occurred to me that potential new customers didn't need to know there had just been a small increase lol.

I'm in vacation mode at the moment so I can finish up a big project. When I go back to business I don't think I'll make a big deal about it. Maybe a small mention in my policies section.

[Dannielle]

The phthalates thing has me completely confused too. Bottom line: I can't figure out if I am required to test for phthalates when I don't make anything from plastic.

Since phthalates are exclusive to plastics it seems reasonable (we are still in the "reasonable" phase of things, right? lol) that non-plastic things wouldn't need testing.

I hate to hang my hat on logic when it comes to all this though.

[Former_Member]

littlethingsboutique
littlethingsboutique says:
I'm torn as to what I'm going to do. Right now, the phthalates issues are weighing me down, blankets and bibs being verboten, apparently, without uber-expensive testing. (I'm feeling a bit German tonight.)

I'll be pulling everything from my stores here and on eBay by Monday p.m. and will have to come up with something about why. It's tough to write, because I don't want any of my customers to think that anything I've sold in the past is unsafe... :/
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I get really bummed when I see people talking about pulling items, the stay of enforcement means it's OK for us to sell while the CPSC gets the necessary rulings worked out. If your items were safe before the law goes into effect they'll be safe after, after all many of us went into this because we WANT safe alternatives to mass-produced items. Your items are wonderful! Makes me wish I had a little one to buy for again.

[Former_Member]

Just remember the stay hasn't "passed" yet. That won't happen until the 30 day comment period and vote. So if you are resonably sure it will pass - keep going and gamble. If you have doubts, pull items and wait and see if it does.

[Former_Member]

Dannielle as I understand it phthalates are exclusively used in plastic and vinyl, so a reasonable testing program would exclude phthalate testing if you aren't using anything plastic or vinyl in your products.

I've seen a lot of people wondering if Velcro is plastic or a textile, any ideas? If it's a textile that would mean it's a viable alternative as a closure for children's products.

[babymoon]

Is there a way to test for phthlates?

[Former_Member]

Thank you, RuthsCreations. You're kind to say.

sugarplumbtree, that's where any hesitation comes from, is that we have that 30-day comment period. I can still sell blocks and balls, but they are a very small portion of my overall sales. Of course, prior to the proposed stay, we had the window until August of "reasonable testing programs" (which I have done). The way things are going, I can't be reasonably sure of anything with Congress/special interests and their litigation/the CPSC these days.

I'm so baffled by the phthalates thing. I don't use plastics, save for the rattles in my blocks and balls. They're easy enough to do without. The main sticking point on that is velcro (polyester) and any polyester ric rack or Minky.

Calgon... take me away!

[wigglysee]

I had my products and supplies tested by XRF and were deemed lead free. I just put a statement in yu shop annoucement that my products have been tested and certified to be lead free.

[Former_Member]

babymoon, apparently the only way to test for phthalates is gas chromatograph (I think that's the word anyway). Anecdotal evidence puts these tests WELL above the cost of lead testing, at around $350 per test.

[Dannielle]

Yeah the only plastic I ever use at all is a few sequins as scales on my mermaid dolls. But I can easily skip them...easy for me to be totally plastic-free.

It's certainly not worth $350 to be able to use a few sequins here and there.

[Former_Member]

I don't use plastics, save for the rattles in my blocks and balls. They're easy enough to do without.
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Wouldn't they be considered inaccessible, though? Or was the accessibility clause only relating to the lead testing?

[StoryBlox]

I thought they decided that XRF testing was not considered reliable as a final test for lead?

[StoryBlox]

Oh, and to OP, there is a certificate you have to issue, but it's sufficient for you to keep the certificate on file and available via a website, here's the form:

http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf

I believe you are required to provide the certificate (or an accessible link to it) to your retailers if you send out any items for resale too.

Don't forget, the laws also require us to put batch numbers and manufacturer information on any item we send out after Tuesday as well... I've yet to find a good explanation of how exactly that has to be done (whether it's sufficient to have it on the packaging, etc).

[StoryBlox]

Regarding "inaccessibility" and phthalates:
http://www.cpsc.gov/about/cpsia/faq/108faq.html#products

"Does the phthalate prohibition apply to inaccessible parts?

The prohibition on phthalates applies to all parts of a children’s toy or child care article as defined in section 108 of the CPSIA. Section 108 does not make an exception or exemption for accessibility for phthalates as is the case for lead in children’s products under section 101."

[Former_Member]

StoryBlox says:

Don't forget, the laws also require us to put batch numbers and manufacturer information on any item we send out after Tuesday as well... I've yet to find a good explanation of how exactly that has to be done (whether it's sufficient to have it on the packaging, etc).

Wait, wait, wait. This doesn't go into effect until August. Right?

[StoryBlox]

I had thought it went into affect Tuesday, I'm not sure what caused me to come to that conclusion... but reading through the FAQ's on CPSC tonight it does appear that that doesn't go into affect until August.

[littlegirlPearl]

August for the labeling.
And phthalate testing just became retroactive 3 days ago. Thanks NRDC...there is a press release related to that. Phthalates might show up in vinyl/pvc. If your bibs are vinyl, you might want to pull them.

[bobbinalong]

Everyone is in such a tither!!! Playing right into the hands of the CPSC and Congress.

If this stimulus package gets passed, and if one of these Senators tagged us into this thing, everything could change. For all of us. And it may not be for the best. The CPSC could drop that stay request.

What upsets me the most is the people that say they have tested and they are okay. I think of all the people selling on here that have no access to testing, that live all across this country, that are disabled, that are military wives, that are older people, that are young people trying to make a dollar stretch, stay-at-home moms, people in rural areas, people that can't just run out and test. On behalf of all of the people selling because they need the money, let's continue to fight this testing thing. Let the CPSC work with the manufacturers, the ones actually producing fabric, etc. - not the people buying from the manufacturers and putting together items.

[Former_Member]

excuse my ignorance but why are you all stressing so ??