New and concerned about buttons and labels

[Former_Member]

So I just started making felt dolls that aren't intended for small children. In fact I've only sold to family and friends (adults). What if these items aren't intended for children at all, will the fact that they are dolls mean that I have to jump through hoops to legally sell these?

My dolls have button/bead eyes do I have to test them for phthalates, etc.? How much would that even cost? Plus, I tend to buy buttons anywhere I can get them, craft stores, antique stores, you name it.

What about labels? When are labels necessary and how do I go about making/getting them?

I am very new and very discouraged by all this. Do I have to stop before I even start? So many questions I need to have answered.

[SewFunDollClothes]

Sorry, but whether you intend your dolls for children or not, if they appeal to children, or are likely to be purchased for children, the CPSIA might decide you need to comply with this law.

And yes, unless the CPSC approves of component testing, as of Feb. 2010, all buttons, zippers, snaps, etc will need to be tested.

Tracking labels have been required since August, I make my own because I don't sew fast enough, or list in such quantity that I can order labels in bulk. The date of manufacture would expire on a bulk lot of labels before I got 'em sewn in to my items.

[Former_Member]

Its a major pain in the HEAD for sure. I suggest reading up on what you can, track where you get your supplies...i need to read more about this tracking label thing...But there is a sentence in the law that says that fines will be given to those KNOWINGLY selling items over the legal limits. And if you are buying from retail stores like JoAnn WalMart, isn't it their responsibilty to make sure the products they are selling legal? Don't be discouraged! Keep going!

[Former_Member]

Actually, no, it's the seller's ultimate responsibility to make sure their items and components are CPSIA compliant. If you can't get certification from the company you deal with, then choose another one.
About the dolls, I'd put a disclaimer on them or their packaging: "WARNING: This is Not a Toy. It contains small parts not safe for children. It is for display only and not intended for use or handling by persons under the age of 13." If you do this, you don't need the labels or the testing.

[Former_Member]

simpleadditions - the law says that if the item appears to appeal to children, it will be considered to be for children

Just one of the reasons so many are 'up in arms' over this law

[Former_Member]

So what should I do before Feb 2010? Can I still use my buttons on dolls? There's no way I can track the button manufacturer for most of the buttons I have acquired.

Also, I think I need to close my shop until I get labels made.

I would eventually like to make dolls that are suitable for children.

[SewFunDollClothes]

I still have the doll clothes I made last year that have buttons on them, and will leave them listed until Feb. 2010. I'm also still listing items I made before the tracking label requirement ... I just printed out all my Etsy bills where it shows that the date I first listed it was before the tag deadline.

I too have buttons that my mom had in her sewing supplies years ago, along with buttons I purchased or took off of vintage clothing before this whole CPSIA law was born. I'll probably just sell them as destash to other crafters who make adult clothing.

[Former_Member]

I think I have to close up shop, for now, until I get labels in and stop with the buttons completely ...for a while. I'll probably have to sell them or use them for other non-doll items. This is a huge bummer, because I just bought a bag of wonderful antique buttons that I love to work with!

Clarification Question: Am I no longer allowed to use any kinds of buttons that haven't undergone testing because I make dolls, which may appeal to children under the age of 13? Even if I include a small parts, choking hazard warning on my labels?

I am very frustrated with all of this.

[Former_Member]

powellpommes, the CPSIA is not only about the small parts. It's about introducing addition lead and phthalates into a child under 13's enviroment. To them it doesn't matter if the product is ever going to be near a child's mouth or skin if it is in their opinion cosidered a child's product it must be lower than their published lead level limit and for some products it must also meet certain phthalates level limits.
The CPSIA has said if a product due to it's price or age is considered a collectable then it would not be subject to the multiple testing required to be CPSIA compliant. Only problem with that is they are leaving 1/2 of that determination up to others including consumer watchdog groups and the general public, rather than the artisan or craftsperson and have not published a governmental guideline of what is specifically defined as a child's product.

[Former_Member]

Thanks for the all the info!

I will be working towards meeting their standards ASAP. But I won't be able to really open up shop for a while.
It's okay, the season will come.

[SewFunDollClothes]

powellpommes, Good luck! I found out about this law about a year ago just as I was setting up my shop. Then I pretty much shut down last February when the law took effect because I couldn't afford to test all my doll clothes (not to mention the testing would have destroyed them). It was only after they put fabric on the exempt list that I started sewing again and re-stocking my store.

It's frustrating at times, but well worth the effort to get creative and try to work out solutions to this idiotic law. Your dolls are too cute to give up on!!

[Former_Member]

Thanks, sewfundollclothes, for informing me and sharing your experiences.

I opened up shop in August, without knowing any rules and regulations, but hope to be better informed and just spend time working on crafting and meeting their standards. It's hard though, because I love making dolls! It's sad that it will be hard to find them homes for a while.

[Former_Member]

This is frustrating, to say the least. My dolls are considered art only, not for child handling. I just updated my site today, adding a disclaimer per doll and on my "appearance" section.

I need to read more about this...I just noticed a couple of threads about the laws taking effect very soon next year. I'll hop over to the thread to take a read...

[kidgiddy]

after reading this I was prompted to blog about it today in the hopes we can all still be selling next year the things we love to make!!!!

http://kidgiddy.blogspot.com/2009/11/seller-saturday-we-are-all-sellers-lets.html

[Former_Member]

Zafras,
Just because you sell your items to mostly those 13 & over doesn't mean the government will see your products as primarily for adults. See the CPSC's age determination guideline at http://www.cpsc.gov/BUSINFO/adg.pdf to see how the government defines a doll as being appropiate for children at different ages.
We need to protect yourselves by being careful of how you describe & tag your items, if the government interpets that you are marketing with parents eventually buying the item for children to use they still may decide to fine you for not testing. So listing a handpaint & embelished frame and describing it as "perfect for children's pictures" will get a flagged by the government or consumer watchdog group well before the same frame that says "perfect for displaying your child's school portrait". Anyone making any grey area items like jewelry, art dolls, whismy themed items, etc may have to overtly stress the point that the piece is intended for adults and not children, not only with disclaimers on each item page but by avoiding child related words in our tags & description.

[Former_Member]

Could you sew on,embroidery work, and/or use little hand crocheted yarn buttons instead?

Oh boy! I don't know how this rule/law will apply to my items. I do have buttons on my hoodie jackets. They are wooden buttons. I try to buy wooden, shell or natural buttons when possible. And I won't buy "Made in China" buttons.

[FayeMaloneDesigns]

Check the wooden toggles you are using. If they have a metal eye where they are sewn on then they would need testing. There has also been a recall I believe on toggles because they can seperate from the back. And if the wood has a finish then that could cause the need for testing, unless beeswax or a similar natural finish was used.