Washcloths or wipes? many questions

[SweetBobbins]

Hi. We make bibs and washcloths. Bibs are, in my mind, for use by baby and need labels and they do have labels now. Washcloths are for use by the mother. We currently have them on the wipes, but at $.20 a pop, I'm not sure I can continue to sell these things.

That being said: question 1: "Do the wipes/washcloths need CPSIA labels?"

Question 2: Does anyone have any interpretation on whether a wipe needs a CPSIA label? Is it for a child or for an adult to use on a child? Does it matter?
I get that we need the country of origin tag for FTC, but CPSIA?

Question 3: And what is this new requirement with testing? I know it's been talked about for a long time, but it seems that now we are going to be responsible for testing our products? We make the bibs with KAM snaps, which are certified. But I read that you can't rely on that - that we still have to test each bib variety.
True or false?

I can deal with the labels, it's the testing that has my unsure of what is next. . .

Thanks!

[FayeMaloneDesigns]

You are correct that the mother is using the wipes/washcloths. However, the are used ON the baby, that is the intended use, so I would say they are definately a child's product. It is incidental that they may be used to wipe the hairchair tray after they are used to wipe the baby's face and hands.

And if they are used strictly as bottom wipes, they are intended to be used only on the child.

But,*******

There is an exception in the labeling if the CPSIA label will interfere with the use of the product, and there is another for sets. For example a hair bow couldn't accomodate a CPSIA label, so a paper tag could be attached. A set of blocks could be sold with a fabric storage bag rather than trying to label each block.. The CPSIA label for the blocks can be sewn on the storage bag. So think of a way to package the set, and put one CPSIA label on the storage bag or box.

Now FTC is different. generally the FTC labels must be on the item. On a washcloth or towel, (I happen to have a dishtowel set on my desk as I am embellishing some plain ones) each one needs labeling,

Hope this helps.

[SweetBobbins]

Do you need seperate lables for CPSIA and FTC and if they get in the way of the intened use does the FTC make exemptions as well. The labels make the products difficult to use.

[SweetBobbins]

Country of Origin Labeling, do you know anything about requirement for labeling country of origin to comply with US laws. I have heard that shipping to some foreign countries also requies you to list Made in the USA.

[SweetBobbins]

Faye Malone Designs -

We were on this website:

http://business.ftc.gov/documents/bus21-threading-your-way-through-labeling-requirements-under-texti...

and found this information. We have been putting one label for our whole set of wipes. They are sets and so it looks like they only have to be on one wipe, It also looks like they can be placed on hang tags and not actual sew in labels.


Products with two or more items of the same fiber 45
If garments or other textile products are sold in pairs (such as socks, mittens, or gloves) or ensembles (such as a suit or a set of dinner napkins) of the same fiber content, only one part of the pair or ensemble needs to be labeled

Label placement and attachment
•The label(s) with required information must be securely attached to the product until it is delivered to the consumer. However, the label(s) need not be permanently attached.

[FayeMaloneDesigns]

Double check the care labels. If I'm not mistaken they are the ones that must be attached, while the country of origin of the fibers may be on a hang tag. They are really 2 separate labeling issues. But they can be combined one one tag.

Some people are putting CPSIA info and Ftc info on one tag. We don't have a ruling on that, so don't really have information that it is really okay. FTC, the Federal Trade Commission and the CPSC, Consumer Product Safety Commission are two different government agencies, (that's how the government makes jobs, lets get 2 sets of thousands of people are doing similar jobs) ,.

I happen to make my own CPSIA labels on my printer, and have FTC and size labels that I bought in woven ribbon that I bought from NWTag.com.