Well the difficulty as I see it, is that they are trying to use an umbrella regulation that isn't a one size fits all. But the end goal is to make safe products for our children.
I think they do realize that there are several categories of manufacturing. They did speak to the small batch production and that there are two categories in this as well; those that have employees and a small out of house building, and those of us who work out of our home that are just us. They also mentioned having to come up with something for those of us that make one of a kind products.
The general consensus is that it is impossible to only have component testing at the factories that make the components. There are too many counterfeit companies out there. So just having a certificate of compliance from a company isn't going to be enough, because even those certificates are being counterfeited. There is going to have to be testing on the part of the manufacturer at some level. What that level will be for us, we will have to wait and see.
What you heard over and over though was that there needs to be flexibility in how compliance is achieved. I think it was well said, when during the small business break out, someone mentioned we need a couple paths that we can choose according to our business and the expense.
For now what we do know is that fabric is exempt, unless you change that fabric by putting a decal, or iron on, or silk screen, or embellishments on it. Natural materials like bone, wood, stone and natural leather are exempt; unless you add coatings or dyes or any other chemicals to them.
The best thing to do is to bookmark the CPSC website and keep an eye on things. It would be good for all of us to read the current regulations as well so that we are all up to date on requirements. For example, the labeling requirements. We all want to be taken seriously in our businesses and therefore need to follow the rules.
There have been many people championing for us small manufacturers on this product testing regulation. And their voices have been heard, otherwise these past two days of workshops would not have happened. We are so grateful to those people. It has all come a long way in the past year. We shall see what happens next.
I believe in what I do; and I know each of us are competent in handling anything that comes our way. We are creative people after all.
