Is there such thing as a CPSA certificate?

[Former_Member]

Hi, I am writing a business plan & working on grants for my business.I am researching all the permits & licensing I need to be legal.
Recently I was talking to a childrens boutique manager that showed me her folder of vendors "Consumer Product Safetey Act" Certificates.
I am wondering if this is something I apply for with the CPSC (can't seem to get through on the phone to ask them)or is it a statement vendors drew up themselves once they complied with the testing & labeling requirements for their product?Does anyone have experience with this?

Also I requested a statement from my fabric wholesale company about the results of their product testing . Now I wonder what do I do with this statement?

I read on the FTC sight that trim & thread was exempt if not more than 15% of product.That I just state on the label "excluding trim".Curious about buttons & zippers.Do I need a testing statement from those manufacturers as well?

I am not sure if I am on the right track.I am trying to get the whole picture here of what exactly I need to do to sew a cotton product (girls dress,purse ect) & sell it legally.

Testing,labeling,certificates,RN numbers does this sound right? Am I missing anything?

I know this was long & I appreciate if you took the time to read the whole thing!If anyone has any helpful experience I'd appreciate it.Didn't see anything already posted specific to some of my above concerns.Thanks

[Former_Member]

Have to go pick up my kid from child care.I will be back later & read & respond or repost- thank you!

[Former_Member]

I am trying to see the bigger picture does this sound right?To be compliant with CSPIA & FTC I need to:

* properly label my product

* test it or can I get a statement from the fabric co. who tested it?

Did I miss anything?

Thanks!

[Former_Member]

Being compliant with the CPSIA is more than just labeling and testing there is quite a bit of record keeping and additional research that may have to be done regarding specific product that have additional CPSC regulations like small parts testing, sizing & construction values for crib linens, or flammability testing for sleepwear or toys. If dealing with fiber based products in most cases you also have to deal with laws and regulations put forth by the FTC a completely seperate federal agency. You may want to see if you can get help from your local SCORE mentor or the regional SBA office in obtaining professional legal advice about making and selling specific products due to the complexities of the CPSC, CPSIA, and the FTC.

The "Consumer Product Safetey Act" "Certificates" that the boutique manager showed you are most likely GCC's issued by the product's maker or the distribitor that the retailer has their proof of compliancy. These certificates are issued by the last person or company that had production value in making the child's product based on testing results or exemptions that basically show at a glance that all the laws and regulations under the prevue of the CPSC have been followed. The GCC is like following a chain of evidence the government needs to be able to look over this document and be able to back track from what's listed on it to the supporting documents like test reports, other GCCs from components, or proof of exemptions.

As for contacting the CPSC by phone about the CPSIA, pretty much forget it. Your best bet is to have either a a legal professional or representative from a trade organization (like Fashion-Incubator or Handmade Toy Alliance) send your question via snail mail to the CPSC. Then keep an eye open for it to pop up on the CPSIA website, because they don't always send personal responses back to the sender.

For more information start with these sites that you can form your questions for the SCORE, SBA, or legal professional to keep the conversation concise.

The main CPSC website
http://www.cpsc.gov/

The CPSIA main website
http://www.cpsc.gov/about/cpsia/cpsia.html

The CPSC's age determination guideline http://www.cpsc.gov/BUSINFO/adg.pdf

Tracking labels required on every product for children under 13
http://www.cpsc.gov/about/cpsia/sect103policy.pdf

For the current full list of raw materials offically exempt from CPSIA lead testing read http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf

An update on the stay of 3rd party & component testing
http://www.cpsc.gov/cpscpub/prerel/prhtml10/10083.html

For a list of accredited labs and what tests they are permitted to do under the CPSIA http://www.cpsc.gov/cgi-bin/labsearch/

Standard Operating Procedure for Determining Total Lead (Pb) in Children’s Metal Products (Including Children’s Metal Jewelry) found at http://www.cpsc.gov/about/cpsia/CPSC-CH-E1001-08.pdf

Standard Operating Procedure for Determining Total Lead (Pb) in Children’s Non-Metal Products read more here http://www.cpsc.gov/about/cpsia/CPSC-CH-E1002-08.pdf

Overview of what needs to be on a GCC
From http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf

CPSIA guidance for small businesses/crafters includes a quick look guide Table : B exempt raw material list
http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf

A general overview from the CPSIA for Small Bussinesses
http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.html

A gateway page for summeries of the law by subsection
http://www.cpsc.gov/about/cpsia/legislation.html#summaries

A timeline from the CPSIA http://www.cpsc.gov/about/cpsia/rulemaking.pdf

Also the lead testing and phthalate tesing is retro-active as considered by certain states Attorney Generals' offices
http://www.cpsc.gov/library/foia/advisory/317.pdf


Small 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.


FTC main
http://www.ftc.gov
Clothing, accessories and home furnishings care and content labeling
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying

You may want to also search at both the CPSC and FTC main pages by specific product type to see if other articles and regulations come up that apply only to that type of product.

[Former_Member]

How lucky am I to get you to respond to this?!Very! I saw some of your past posts & know I got the right person to help!This is really fabulous,Thank you so much!

I did realize yesterday while researching those 2 sites(CPSC & FTC ) that each ingredient in my finished product would have to be researched before I could label.

I was wishing I had a professional or mentor to speak with for legal advice.So many of the terms & statements I read I didn't know how to interpret.Such as 3 rd party-who is that exactly? Me? So thank you very much for the leads!

This seems terribly complicated so far, especially since it is all new info to my brain.I have been making several different products for years.Looks like I should start with one & get it down perfect before I add to my selection of products I make.

Thank you so very much!!

[Former_Member]

marking

[FayeMaloneDesigns]

3rd party is definately not you. Nor is it the CPSIA, or a retailer if you are wholesaling. It is a lab that has been certified by the CPSC to be qualified to test the products using the testing protocol that is required to give the most acurate results. Now if you are Mattel, and you have an "in" with the gov. then you can get the CPSC to allow you to have a "3rd party" lab in your facility. Not they would show you (Mattel) any favoritism, just saying.

[Former_Member]

peanoonies says:
I read on the FTC sight that trim & thread was exempt if not more than 15% of product.That I just state on the label "excluding trim".Curious about buttons & zippers.Do I need a testing statement from those manufacturers as well?
...........

Someone please correct me if I'm wrong, but as far as I know this rule just applies to the wording on Care & Content labels. Like if you have a cotton apron with polyester embroidery, you can say "100% Cotton Exclusive of Trim." or- "exclusive of decoration". It exempts it from being listed on the label, but not from being tested. Unless it's an exempt material. most thread is, so maybe that's not the best example! eh- Friday afternoon, that's the best I can do.
:-)

[Former_Member]

I just got my pacifier clips certified by a 3rd party lab that is accredited by the CPSCIA to do the testing. I have my test results from them that certifies my products are below the CPSCIA stated requirements for lead/pythlates.

I didn't know what I first needed to do when looking in to getting them tested & I called the lab & they were super helpful. I also called the CPSC to ask them some other questions also. CPSC is also very kind & helpful to call.

GOOD LUCK!!!!

[Former_Member]

marking

[Former_Member]

Marking

[Former_Member]

Oh this is such great helpful info,thank you all!

amyblandford - yes that is what I read concerning contents labels.I just began my research so I don't know yet what more there is to that.
O.k Whimsicail,you were able to get through on the phone?Then I will keep trying!

Thank you for clarifying who the 3 rd party is! So now do I just look up an approved by the CPSCIA lab on the internet?Perhaps if I get through on the phone they will tell me of one.

[Former_Member]

whimsicailLo or anyone , just curious what it cost you if you don't mind sharing to test one thing? Everyone keeps saying it is very expensive.Was wondering how expensive.I realize I still have to research for my own product & it may be more or less, but I have no reference to even imagine what it is around.

[Former_Member]

marking

[Former_Member]

I have done some research from the links provided here in this thread, & will continue to do so but please forgive me for asking another question that maybe should be clear to me by now but isn't.

Is the CPSIA testing & regulations soley for products intended for children 12 & under?

If I make a womans cotton textile purse today & properly label it according to the FTC rules am I good to go on that product? Thanks!

[FayeMaloneDesigns]

Yes you are good to go on the woman's purse.

[Former_Member]

Thank you! Trying to contact CPSC.What I am understanding so far is I must get my childrens cloths tested regardless if my supplier has already tested.
O.k so do I test locally? How do I find this lab? Anyone know the goin rate? I emailed & called CPSC but am not sure if they will get back to me. I have to get this business plan for my grant under way, I am a broke single parent who just became unemployed! The heat is on!

[Former_Member]

Never mind found lab list from previous post-thanks