Sending handmade Items to other countries

[BeachEndQuilts]

Are there laws that we should be aware of concerning labeling prior to sending our items to other countries? Are we subject to the labeling requirements of other countries?

[HookedByNurseSharon]

good question

[HookedByNurseSharon]

just an fyi...i had questions about buttons and rhinestones for children 3 and older. I emailed CPSC and got some great and easy feedback. I saved it to a word document and put a copy in my legal documents binder. Convo me if you would like a copy of the email. He was really helpful

[BeachEndQuilts]

I just did, thanks!

[FayeMaloneDesigns]

Allison, If you are following the CPSIA and the FTC laws, and attaching the correct labels for your products that should suffice for other countries. Our safety laws are comparable to other countries safety laws.

The USPS has a list of items by country that you can not import to that country. So you should at least read thru the prohibited list and see if you make anything on that list, and you will have to not sell those items to that country

[FayeMaloneDesigns]

Sharon, would you post Neal's response to you regarding buttons and rhinestones, we would probably all benefit. Thanks, Beverly

[HookedByNurseSharon]

Absolutely! Here you go :) just read from the bottom up since its and email feed.

Sharon,

Ok, now I’m ready to answer your questions.

First, you have your congressmen and our Commissioners to thank for being exempt from third party testing as a small batch manufacturer. Third party testing is very EXPENSIVE and we are not trying to put cottage industries out of business.

Next, you can put embellishments on the hats intended for children 3 yrs and above, such as acrylic rhinestones/buttons and satin ribbons. The buttons would have to meet the lead standard, which is <100 ppm for plastic and <90 ppm for any painted buttons. In order to do this, you NEED to have your supplier send you a letter documenting that the buttons have been tested and meet the aforementioned CPSIA lead standard. Also note that unpainted wooden buttons do not have to be tested for lead as they are a natural product. If they are painted, then they do have to be tested. This puts the testing burden on them and many manufacturers will only buy component parts that have been tested and certified by the supplier. Phthalates only come into play if the embellishment is a soft type of rubber, as the purpose of phthalates is to make rubber soft. I have never seen a soft rubber button, so I think you’re OK there.

I know a lot of small manufacturers and second hand store operators feel there is a big disconnect between them and the CPSC, but our website, www.cpsc.gov, is getting better all the time. Please utilize Neil Cohen using the contact information I provided in my previous email. He’s there for small businesses. My primary responsibility is monitoring the northern border of New York for unsafe products, but I am more than happy to help with questions when I can. Please feel free to contact me anytime and I will provide the answer or find out what the answers are.

Regards,
Doug

From: Sharon Steffens [mailto:hookedbynursesharon@yahoo.com] 
Sent: Monday, July 15, 2013 6:17 PM
To: Pinheiro, Douglas
Subject: Re: CPSIA Questions

Thank you so much Doug for your reply. This really helps.

Since I am not required to have my products third party tested,
1. will I be able to put buttons and embellishments such as acrylic rhinestones/buttons on my hats for children older then 3 yrs of age?
I understand that there are lead and phthalates regulations.
2. What are the regulations and requirements if would like to put these items on childrens hats/accessories for the ages over 3 yrs old?
3. Do I need a letter from the manufacturer at all? Ex. treated/darkened colored wood buttons, plastic buttons, acrylic rhinestones.?
what about ribbon such as satin ribbon on hats for baby's through age 12? is that ok?

I guess I don't understand why I am exempt from third party testing of all products just because I'm registered as a small batch manufacturer.

I really really appreciate your answers. I can pass this info on to my fellow etsy sellers of baby items.

Your feedback is valuable information :)
sharon



From: "Pinheiro, Douglas" <DPinheiro@cpsc.gov>
To: Sharon Steffens <hookedbynursesharon@yahoo.com> 
Sent: Monday, July 15, 2013 2:17 PM
Subject: RE: CPSIA Questions


Sharon,

First let me answer some of your questions.

1. You need only register as a small batch manufacturer on the www.cpsc.gov website
2. You have to register yearly
3. As a small batch manufacturer, you are NOT required to have your product/s third party tested. As an FYI, acrylic fiber has always been exempted from flammability testing under the Flammable Fabrics Act (FFA).
4. The addition of buttons or other embellishments to products intended for children under 3 years can create a choking hazard, so by excluding them you will not be setting yourself up for possible liability claims. It is illegal to have small parts on products intended for use by children under 3 years of age.
5. The tracking label you presented below is fine if the lower alpha-numeric information is a date code. You do not need a batch number.
6. That’s all the labeling you need for us, but you may need care instructions, but that is a different agency.

For additional information, visit www.cpsc.gov, click on the “Business & Manufacturing” blue tab at the top and then “Small Business Resources” from the drop-down menu. There is also a toll free number, 1-800-531-9070 and a “contact form”, which is a platform for asking questions.

If you have any other questions, please contact me.

Regards
Doug Pinheiro


From: Sharon Steffens [mailto:hookedbynursesharon@yahoo.com] 
Sent: Monday, July 15, 2013 1:27 PM
To: Pinheiro, Douglas
Subject: Re: CPSIA Questions


Inquiry:
Hi, I am in the process of opening an online business on etsy.com selling baby and children handmade crochet hats made with 100% acrylic yarn and no buttons or embellishments. Most of us start etsy stores as hobbies and had know I idea about CPSIA until certain members just happened to bring it up. I have spent hours researching the CPSIA website in order to comply with it's regulations but I still have a few questions.

1. I just started the registering process for the small batch manufacturer. Do I need to register anywhere else according to CPSIA. I need to register as a small batch manufacturer yearly?
2. I ordered tracking labels with the following info to be secured on each hat.
Hooked From The Heart
hookedbynursesharon.etsy.com
Made in the U.S.A.
Waterford, CT
13JASONDJFMAMJ14

Does this look acceptable for per regulations of CPSIA?
3. Is it required that I put the size of the hat directly on the hats that I sell for babies? (Or can it just be on a hang tag?
4. Is there anything else I need to put on my baby hats as far as labels?

From: "Pinheiro, Douglas" <DPinheiro@cpsc.gov>
To: "hookedbynursesharon@yahoo.com" <hookedbynursesharon@yahoo.com> 
Sent: Monday, July 15, 2013 11:49 AM
Subject: CPSIA Questions

Hi Sharon,

I was recently made aware of the website, www.etsy.com, that appears to be an arena for CPSIA questions from the cottage industry. The Consumer Product Safety Commission is the federal agency that has impletmented and enforces the CPSIA regulations. From looking at this site, there seems to be a lot of questions on the CPSIA, which can be confusing as it has changed so many times. I would be interested in hearing from you regarding what the Commission can do to better serve the needs of the cottage industry.

Regards,
Doug

Douglas Pinheiro
Compliance Investigator
Office of Import Surveillance and Inspection
U.S. Consumer Product Safety Commission
Phone: 716-648-9278
Fax: 716-866-923-0903
Cell: 240-429-4008


*****!!! Unless otherwise stated, any views or opinions expressed in this e-mail (and any attachments) are solely those of the author and do not necessarily represent those of the U.S. Consumer Product Safety Commission. Copies of product recall and product safety information can be sent to you automatically via Internet e-mail, as they are released by CPSC. To subscribe or unsubscribe to this service go to the following web page: http://www.cpsc.gov/en/Newsroom/Subscribe *****!!! ­­

[HookedByNurseSharon]

I just read the emails again. it looks like easy was labeled as a "cottage industry" and in the upper email mentions that they are trying to put "cottage industries" out of business? hope that's not true

[BeachEndQuilts]

If you will reread the letter, he says they are NOT trying to put cottage industries out of business. He also says he has never seen a soft rubber button, I have! I bought a shirt years ago that had buttons like that.

I'm glad to know that our FTC and CPSIA labels will be good for sending our handmade items out of the US. Now I am off to look at the USPS prohibited items.

[HookedByNurseSharon]

Thank you for the correction Allison...I was hoping that wasn't true...(sigh)...it's been a long week...selective reading. LOL!

[HookedByNurseSharon]

He was really really helpful and open to our questions to him.