Numerous questions for complying with CPSIA

[Former_Member]

Hello!

I just recently learned about the CPSIA and realized that I have not been complying with all the regulations for my products. I got my SBM# yesterday.
I've figured out most of what I need to know through the CPSC website and Neal's post in this group but I still have lots of questions that I need answered.

If any question can't be answered, I can contact Neal as well, but I figured I would try here first.


1. Where do I go to see a full list of materials which require testing or those which are exempt?
The materials I use are: thread, polyester fleece, felt, Poly-fil, metal wire, metal safety pins, metal hair clips, and plastic headband inserts.
I've read that fabrics/thread are exempt from lead testing, and I have the test results from my supplier for the headbands, but I'm uncertain about the metal items.

2. Where do I go to see the list of citations for each CPSC product safety regulation which I will be stating in my CPC? (I tried to follow various links here and on the cpsc page, and got a page with no info on it from a different website)

3. Do I need a CPC for each individual item, or can I combine many similar products made with exactly the same materials under one CPC?
Most of my products use exactly the same things, but are different by color or pattern.

4. Do I need to send the CPCs to anyone or just have them on hand?

5. On the CPC form where they want you to put "Date and place where product was manufactured" they ask for month and year, but I make each product to order. Can I just state the year, and update the file for each new year?

6. Do I need to have my items tested for small parts?

7. This is an FTC question actually...
I believe my animal headbands qualify as "hats, or anything worn exclusively on the head" so they are exempt from needing a "Care Label", but I also sell matching pin-on tails (cat, mouse, etc) Do you know what those would be considered? (toys, or clothes or...?)

8. Lastly, do I need to keep a running record of materials and costs for every single sale, or can I just have a list of materials, costs and price for each item, regardless of when and how many sell?

Thanks so much for any help you all can offer.

[Former_Member]

Oh, and I forgot to ask: Should I be worried about getting in trouble for not complying with all these regulations before now?

[Former_Member]

Hi Jenna (or Loli!)

I can help with some of your questions as I had the same ones.
As for the CPCs, you can combine them for similar items. For example, I make crib sheets for my store so I can put all crib sheets on one CPC. I just have to include the tracking numbers for each sheet and make sure they are on there. You can keep updating them with dates and id#s as you go along. You keep the CPCs on hand for your records. If you happen to sell your products to a store for them to sell, you provide the CPCs to them as well.
As for updating them with the date for custom orders, I assume you can figure out a way that makes sense to you. For example, if you make a tiger headband to order you can have a CPC for 2014 with the tracking number for all the headbands you made that year. Maybe after each tracking number you put the month in parenthesis. Then create a new CPC for 2015 to keep track of the custom orders for that year. Just a suggestion to keep things more organized and easier to reference should you ever need to.

As for tracking raw materials and finished inventory, I believe for IRS purposes you have to track both. I have a spread sheet that has all the raw material purchases I made and a final column where I put the tracking number for the finished products that the raw material produced. It also helps me keep track of things like cost per yard so I can better price my finished products. I then have a spreadsheet with all my finished inventory with tracking number, date produced, material make up, cost to make, date sold, and who I sold it too/order number.

And I wouldn't worry about getting in trouble. You are doing your due diligence to follow the regulations and I am sure you weren't intentionally selling anything unsafe!

I'm still swimming through the regulations too to make sure everything I will be selling is in compliance. I actually spoke to Neal a couple of times and he is really helpful if you ever do need one-on-one help!

Good luck!

[Former_Member]

Hi Janelle,

Thank you so much for your response!
Putting multiple items on one CPC will make this whole process less stressful.

One more question:
How do you come up with the tracking numbers for each item?

[Former_Member]

I made them up. They are for my purposes only. You can number your items however you like. I put a letter in front of each type of item. For instance, my crib sheets are numbered C01, C02, etc. My blankets are numbered B01, B02, etc. I use a satin pen and mark them each on the inside of the care label. It's a fold over so it isn't as visible but still accessible.

[Former_Member]

Hello, I am new here and I too am very confused about CPSIA. I read on another discussion that you only need a CPC form if your wholesale.Also I thought you don't need a tracking number other than date of manufacture on the tags.
Jenelle is this for your own purpose? I would love to see an example of your spreadsheet for IRS purpose. Thank you.

[Former_Member]

Hi Faye,
I'm new to this as well, but with lots of looking around online and reading threads I am starting to get things figured out. The way I understand it is that you need a CPC for any items which are intended for use by children 12 and under. The purpose of the CPC is to outline that each item you are selling is compliant with the various regulations pertaining to it. You can read about CPCs and look at two examples here:
http://www.cpsc.gov/cpc

As for the tracking numbers, you do need to have a "tracking label" which has something similar to the following information:

Faye Malone Designs. com
Kinsman, Oh USA
Handmade in the USA
of imported fabrics
14 15 SSFW 16 17

That is the one that Beverly, the team captain, posts on other threads as an example from her business. She just marks underneath the year and under SSFW (spring, summer, fall, winter) for when it was made.

Actual numbers on at tag which are recorded in a spreadsheet seem to be mainly for personal use. I don't think businesses which are registered as Small Batch Manufacturers are required to put tracking info on the product other than the information stated above, though even that is not required if the product is too small to have a label. (My headbands are too small, so I'll just be attaching the "tracking label" to each package.)

[Former_Member]

I found the answer to my first question by googling for the list. Turns out I'll need to get my hands on lead test results from the manufacturers for the metal safety pins and wire, or just try to remove those materials from my items for kids.

I'm still hunting for answers to questions 2, 6 and 7, if anyone else can pitch in advice. :)

Thanks!

[Former_Member]

Faye,
Do you still want to see my tracking sheet? I can email it to you if you would like.

[Former_Member]

Hi Jenelle

I'd really like to see your tracking sheet!

Liz

[Former_Member]

Jenelle , that would be great!!

[CozyChipmunk]

Jenelle,

I'd love to see your tracking spreadsheet, too, if you're willing to share! :)

Thanks!

Daryl