!. Yes
2. Just simply state in your description or your policies or about page that you follow all CPSIA regulations for safety and that you are a registered Small Batch Manufacturer. You do not give out your number, think of it as your SS#
3. If you have certificates from your suppliers that all the components are certified, no you shouldn't have to have them recertified, BUT, if the composite of the supplies changes the product to something that falls under a different regulation then you might need to test for that.regulation
For example if I make a jacket the fabric is exempt from lead testing per 16 CFR 1500.91 and flammability testing is exempt from the SBM registration,and the buttons are exempt from the Small parts regulations per the SBM registration, BUT I add a drawstring (of an exempt fiber) to the hood of the jacket, then I have made the total product in violation of the drawstring regulation and subject to fines and recall.
4. Yes testing is not cheap. But remember you make a product that is outside the norm and a special needs product. Your liability is higher as the usage is different than the parameters of the regulations Do you have liability insurance to cover you? Are their any recognized trade organizations that cover your special needs products? I am worried that you feel if each supply is exempt that you are free and clear of any liability and are compliant. It's more complicated than that. I am not sure that you are. You are making a specialty child's product. Truthfully, I would spend the money to have your completed product tested, not just the individual components. You need to be completely open with the testing lab explaining with pictures if possible what you need tested and how, with ages, the users you market to. We aren't just concerned about lead limits in each component, it's the question of the completed teether, does it pose any hazard to a special needs child in use, and are their any warning that should accompany the instructions.
