Thank you for your help!
The bandanas are 100% cotton and printed with modern techniques. They are custom printed with the company's logo, but are ink printed (NOT screen printed), so the ink soaks into/becomes part of the fabric and there is no raised transfer or paint layer that could peel off.
The front of the bibs will be made of a combination of plain surface cotton fabric and the cotton bandanas. I wanted to make the back of the bibs out of terry cloth (towels) or flannel, but those seem to be a problem for flammability, so I may use polyester fleece. Do you know if flannel or terry cloth can be used on bibs?
So far, I have these citations in part 2 of my COC:
• 15 USC 1278a Children’s products containing lead; lead paint rule
• 15 USC 2057c Determination of Phthalates in Toys and Certain Children’s Products
• 16 CFR Part 1501 Small Parts Rule
• 16 CFR Part 1610 Standard for the Flammability of Clothing Textiles
And I have these exemptions listed in part 6, along with my SBM#:
Exemptions for lead content:
16 CFR 1500.91(a)(6) CMYK process ink that becomes part of the substrate
16 CFR 1500.91(a)(7)(i) Natural Fibers (cotton)
16 CFR 1500.91(a)(7)(ii) Manufactured Fibers (polyester)
Exemption for Phthalates—No plasticized parts, so product contains no phthalates
Exemption for Small Parts—16 CFR part 1501.3(d) Children’s clothing, (e) Feeding products,
Also, no small detachable parts
Exemption for Flammability Testing:
16 CFR 1610.1(d)(1) Plain surface fabrics weighing 2.6 oz/yd2 or more
16 CFR 1610.1(d)(2) Fabrics made entirely from polyester
If I use the above citations and exemptions, I *think* I am covered without doing any testing, as long as I keep good records from fabric bolt ends, dates of purchase, etc. Am I missing anything?
