If all parts are approved do I need to have my product tested?

[Former_Member]

If the cloth I use to make clothes and pillows and blankets and diaper covers for babies, toddlers, and kids is exempt from the testing rule, and the fasteners I use (snaps, buttons, zippers, etc) have been tested by their manufacturer, does my work need to be tested before I can list it for sale, or can I label it as "approved" because all parts are approved?

Is the testing JUST for lead, or am I reading the CPSIA materials incorrectly?

[Former_Member]

Cloth is exempt as long as it is not a screen printed pattern or has a "metallic" threads or has been treated with a plastic. For the fasteners or other non-exempt add ons you need to have the actual test results, for now a report with a description of the component with the batch/lot #, date of testing, testing method used, the lead and if needed the phthalate levels reported in PPM, along with the lab's name or the tester's credentials. You need to be able to trace which test results go to which of your products and the customer needs to be able to track the product back to you even when they did not purchase direct from you. So tracking labels are still required even if your finished item is made of 100% exempt components. Phthalate testing may be needed if your items are to aid or promote the care, feeding, or sleeping of a child 3 and younger or if your products meet the government guidelines of what is considered a toy for a child under 13.
You can not state that a product is CPSIA approved but you can mention that all the components and raw materials used meet the CPSIA's requirements or are exempt from CPSIA's testing or that the finished product is CPSIA compliant. The CPSIA does not approve of any products they are just in charge of enforcing and interpeting the law, even if the finished product is tested at a CPSIA pre-approved lab it does not mean there is a "stamp of approval" issued by the government.
Remember in addition to the CPSIA there maybe other regulations and laws that need to be followed under the CPSC or the FTC. It's best to check out the different agency's main websites to see what comes up under a product specific search.
Things may change at any time, so it's important to keep checking the CPSIA pages at the CPSC website to see if they update or issue new protocols and procedures about testing or other subsections of the law.

[Former_Member]

Thank you! I also just saw that there will be an event with the CPSA about the regulations on the 25th of March so I marked that on my calendar. I'm sitting on my stock of items waiting to finish setting up my shop because I'm confused about the regulations and don't want to be "illegal"! Thank you for your help.