My take on the letter is here:
http://heartkeepercommonroom.blogspot.com/2009/01/cpsia-updates-they-want-to-be-legal.htmlI think books will be exempt. I think dyed fabrics, if shown to be below the lead limits in general, will be exempt, and thus so will clothing that is not made with any "painted, plastic, or metal components"- no snaps, buttons, zippers, etc- in fact, they issue a veiled warning that the Commission had better not exempt any such items.
I think the letter does not correct any misinformation, and it makes it clear that the so called 'clarification' for resellers is not much of one. In fact, they tell the Commission to go back to thrift shops and resellers and talk to them some more,
"as they sell large volumes of apparel, it is critical to increase their understanding of the law in order to ensure compliance with the lead limits and proved them with guidance on appropriate measures of due diligence to avoid liability under the statute."
To avoid liability sounds like they are not board with the commission's promise that nobody is interested in going after them, just the 'Big Guys.'