Just so I'm clear...

[DeathMetalMama]

If I use sewn-in fabric ties, elastic covered by fabric, and non-metallic/waterproof/coated fabric, and no buttons/snaps/zippers, I'm exempt from all testing.

This is what I'm understanding. Is this correct?

[FayeMaloneDesigns]

I don't know what you are making, but looking in your store, it appears that you dyed a baby outfit pink. Your pink dye will have to be tested. Tea dying will not as tea is a "food stuff" and will not contain lead.

And depending on what the "upcycled fabric" is you may or may not have to test. If the fabric is crease resistant, or no ironing needed, it will probably contain a chemical that makes it crease resistant and that will have to be tested. Or you may have screen printing which will need testing.

You will have to label with CPSIA and FTC labels.

[DeathMetalMama]

I've pulled the pink onesie just to be safe, and the upcycled fabric on the tea stained is simple black jersey knit from an old T-shirt.

I have been thinking about getting a screen printing set up, but even water based Speedball inks have to be tested?

The main question has to do with a line of clothing I'm thinking of starting up. I was wondering if I kept it within the guidelines I mentioned in the OP, if I would be exempt from testing.

[DeathMetalMama]

Also, this is the link I read regarding fabric dyes and testing, before I dyed that batch of pink onesies. Is it false?

http://www.dharmatrading.com/info/lead/

"They have also now exempted dyed fabrics from the lab testing and Certificates of Compliance requirements, as they have finally figured out that dyes do not contain lead, so that is very good news for all of our customers who use our dyes. Our dye manufacturers have basically told us that since they do not market their dye to be used by children, they do not intend to have it tested for lead, as they have already gone to the expense of having it all tested to provide the MSDSs (Material Safety Data Sheets). However, the MSDS for dyes, or paints, or chemicals, have to indicate whether lead is present, so since they don't (with the one exception of Black Jacquard Acid Dye), and since dyed clothing is now exempt anyway, customers do not have to worry about the dye they use on children's clothing."

[FayeMaloneDesigns]

Yes, it is, in how most of us read the final rules. Current commercial dying/printing processes do not use lead, or in a small enough quantity, it is washed out in the final washing. Home dying is not commercial dying, it falls under the lead in paint rules. MSDS do not show the same lead testing results that the CPSC requires for CPSIA compliance.

Dharmatrading is also incorrect that certificates of compliance are not needed. We need to send GCC's on all wholesale orders to our retailers. We do not send them to our retail sales as we are the retailer. We must keep them on file/or at least all the information so that we can prove that we have dotted all our t's if the gov asks.