Former_Member
Not applicable

Testing of labels?

Okay, this might sound like a really silly question, but do the labels/ink used on them have to be tested?
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Former_Member
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Re: Testing of labels?

Yep
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Former_Member
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Re: Testing of labels?

everything!
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Former_Member
Not applicable

Re: Testing of labels?

That's what I was afraid of! Where does it stop!? Can't dwell...just push on through. Found myself dwelling for a bit there and my sales suffered. Stay focused, stay positive... :)
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Former_Member
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Re: Testing of labels?

Thank goodness I can embroider my labels

Linda Ooooo
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Former_Member
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Re: Testing of labels?

Seriously, I think that would be a great business to go into right now! HMMM....
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Re: Testing of labels?

Kind of funny to test the label that is warning you about lead. :)
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Former_Member
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Re: Testing of labels?

Wow...this is so far over the top.
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Former_Member
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Re: Testing of labels?

No,I do not believe that you have to test the label as long as the label only makes up a certain percentage of the product. I have read through the entire CPSIA act and all of the federal guidelines regarding textile manufacturing. Even though there is a great deal wrong with the CPSIA act including many arbitrary testing standards, testing garment labels is not the concern. The act in the final analysis is meant to serve as a reorganization of the CPSC's role in public safety. It's also intended to underscore not change some of the laws regarding products that were already in place and that were often being ignored--the CPSIA provides stiffer penalties and guidelines for applying those penalties.

I am not in favor of it by any means--I think its intent is good but its application is poor. I also believe that many people are falling into inaccurate information which can make a bad situation much worse.

Take for instance the labeling law--I have no clue why anyone who has dealt in textiles is so upset about this aspect of the act and I certainly don't know why many are referring to it as "new". The CPSIA act primarily underscores the textile labeling acts that have already been in place for 20 + years. The only additions are the necessity of batch numbers and manufacturing dates. As clothing makers we were always supposed to properly label the content of our garments and our company's identifying info with permanently attached labels(ie. sewn in for us) Having those labels was never a marketing "plus" as many seem to think but a federal requirement---has been for 20+ years. But thinking that there is some extreme "new" labeling law can be very worrisome AND it can hurt the protest against the CPSIA, because it makes it seem like smaller companies aren't knowledgeable about the laws already on the books.

I know its long and heavy reading but I would advise anyone who is making anything for children to sit down and go through the act yourself. That way you can know what is necessary to worry about and get upset about and what might just be rumors.
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Re: Testing of labels?

You are right about the labeling for garments. Everyone should be following those laws, and properly labeling their garments. Adding the additional information to a label may be that burdensome, keeping track of all the exact components in each item is.

If I use 5/6 spools of thread, quite possibly purchased at different times, therefore different batches, I have to keep all the info off each spool, and a sample of each thread.

Same with buttons, I'm looking at 3 cards of buttons that look exactly the same, but one can tell by the cards that they were from 3 different batches. I'm going to have to keep a button from each card, along with the card. I need 9 buttons for the garment, each card has 3 buttons, therefore I'm going to have to buy 4 cards so that I can have a sample from each card. $$ more money spent. It'a not like I'm make 500 garments alike where I only need recordkeeping on 1 button out of 4500 that I purchased in bulk. I'm making 1 dress!

But, I can handle this, but where is the bow maker going to permanantly affix her label? And where on the little girl's bracelet is the label going to go? And what good is a label to the consumer if one needs a microscope to read the printing on the label to ascertain all the info to check against a recall list?

And currently, it seems, if we are making a good faith effort to label our items with the neccessary info, the CPSC will be happy, we think, and they think. But, and this is a big but, they haven't decided exactly what or how they want the labelling to be done. One commissioner wants there to be a stay so that they can set things in stone for all of us to follow, the other commissioner doesn't want a stay, we should just label however, and they will work it out later.

That's just great, so some order labels with numbers, wait 6-8 weeks for them to arrice. Some people order laser cut stamps they can use, and fill in the blanks, some people order something else. And along comes the new head of the CPSC, and the new commissioners, and they change their minds and issue new rules. All that money goes out the window, and no one can sell anything with the old labels. And if they decide we all have to have barcoded labels, we are dead.

I don't find all this rumors. I have been thru the act, the garment labeling act, and have every pdf that the cpsc has issued on this and read everyone of them. This law as written is just the tip of the iceberg that is comming out of washington. Most of them are now in the 900 page range of total drivel that no one has read, and no one has even begun to fill in the details. Everything is left to "figure out later".
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Savantpatterns
Inspiration Seeker

Re: Testing of labels?

Waterfallcrafts: You still have to test embroidered labels :).

Re: "The CPSIA act primarily underscores the textile labeling acts that have already been in place for 20 + years. The only additions are the necessity of batch numbers and manufacturing dates."

If you're a very small producer and hand make each label, this won't be as onerous for you as it is for others. The only change for handmade producers is having to track the components of each "batch" (one item). You can easily do this with a spread sheet, likely copying and pasting your most commonly used materials from one item to another. You'll have to issue a unique batch number for each "batch" (again, one item) and keep this as part of your business records.
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Former_Member
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Re: Testing of labels?

Since component testing is not permitted in the law and the final complete item must be tested,the label would be tested with the item - since it is a permanent label it is a permanent part of the product.

What can get ridiculous is that a permanent label should be put on the label by the manufacturer of the label - and conceivably this could go on and on. This is most likely where the "when practicable" clause would be applied.

Keep in mind that while the current CPSC has made some exclusions and has set a temporary stay - these are not written into the law and are likely to be taken away by the new members of the Commission that are being appointed and the Stay will expire in 2010. The law is as stands and there is no component testing permitted in the law - nor are there any exclusions.
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Former_Member
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Re: Testing of labels?

UGH! It's enough to make me cry! I can't remember where all of my "stash" came from... (Heck, most days, I can't remember yesterday!)

I'm getting a headache from all of this.
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Re: Testing of labels?

Littlethings, I have no idea where my stash came from either. I was a fabric buyer for a clothing designer in the 70's. I still have fabric from then, plus all the new fabric I've acquired since then. I'm ready to tell the gov to stick it up their tea bag!!!

Time for a final glass of wine, 3 tylenol, and a good book. The more I dwell on the joke that is our government in washington, the more I want to vote 99.9% of them out, and also purchase a rosetta language program in mandarin. We are all going to need to be bilingual.
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Former_Member
Not applicable

Re: Testing of labels?

FayeMalone, I could use a stiff drink myself! This situation has really opened my eyes politically. (Having been educated in DC and then living there for several years after, politics has always been one of my most loved spectator sports, but with young kids, time seems to get away from me.) I used to be slightly left of center. I've now rounded the political horn and am heading full throttle into libertarianism!

*uncorking the bottle and pouring a big glass*
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