The only answer I could give you is that for right now, during the stay of testing, that the CPSC is allowing us to use GCCs and COCs from the supply manufacturers. Unless you are making items with paint or jewelry or certain baby items the CPSC is not requiring the finished product to goto the accredited labs for private testing until Feb 10th 2010. Certificates from the manufacturers of the raw materials are to show "in good faith" that we are producing are items within the acceptable lead and phthalate levels. Once the stay is lifted even if you are using using 99.99% of exempt raw materials in your finished items by adding even one element that is not exempt that will cause the whole item to be required to tested as a completed product at the labs. The CPSC is considering component testing but not in the way we are thinking of - the completed item would still have to be sent to the lab but they would only test the raw materials that are not on the exempt list.
Just as an example - A yarn knitted shawl with a single button to hold it closed at the neck is OK now as long as you have some written proof from the button manufacturer that the lead level is under 300ppm and if it's for a child under 3 that the phthalates are under 100ppm for the 6 identified as harmful. But come Feb 2010 that same shawl when completed would have to goto to a 3rd party government approved lab for testing to show that the whole thing is under the same levels for lead & phthalates, because buttons are not on the exempt material list even though yarn is, the lowball price from the labs I've seen for testing is $75 per component. So a single color yarn shawl w/ button would cost $150 to test and a two color yarn shawl w/ button would be $225. If the CPSC does allow their version of component testing to pass the same fee would drop to $75 for testing of the button only.
