screenprinting onesies and the CPSIA

[Former_Member]

hey guys,

i've tried making sense of this CPSIA stuff and i end up confusing myself more and more. here's a basic question i need answered:

i'd love to start screenprinting kids tees and onesies. if i use american apparel's organic blanks and print with non-toxic waterbased screenprinting ink, do i need to do testing or does that fall under exempt?

if i don't do testing, is it enough to get documentation from the companies that produced these items showing they've had their onesies and screenprinting ink tested?

thanks for any input, this stuff is mind-boggling.

[Former_Member]

I've got the answer b/c I haven't yet researched it. Just marking for the handmade store I eventually hope to open.

Thanks for asking the question!

[Former_Member]

Oops. I meant to say I have NOT got the answer. Sorry!

[Former_Member]

awwww you got me all excited!!

[Former_Member]

Once Feb 2010 comes you are going to have to test because of the inks. And you will have to test samples of the final items because component testing (materials testing) is not permitted. Each time you make a tee or onesie that uses a different color ink or you run out of one ink and need to replace it, you will have to test all over again.

Once you look into the cost of third party, approved testing, you will not be happy.

This is the insanity of this law.

[Former_Member]

omg are you serious!!!

so what if i took all the inks i have on hand and put little swatches of all of them on a onesie and have that onesie tested?

i get why you'd have to re-test with every new batch of ink, cuz maybe there's an anomaly somewhere in production where bad stuff got in but SWEET LORD NO!!!!

i've got an email in with someone who's well versed in the cpsia stuff, too, will report back what i hear!

[Former_Member]

Marking. Would like to hear more about this as I was just starting some screens, myself.

[SewFunDollClothes]

pastperfect is right ... and I agree with the "insanity of this law"

We're all hoping CPSIA will agree to component testing when this current 'stay' ends in Feb. 2010. Seems ridiculous that every person using a non-exempt supply should have to test every single thing they use ... when the supplier could batch test and certify it's compliance.

[Former_Member]

Natural fibers are exempt, I believe. So if I use a cotton onesie or shirt, but then make my own vegetable dyes.....not sure if that even works for screenprinting. I need to read a whole lot on the .gov website in the next few weeks, but it's the pending status of the component testing that makes it so difficult to continue down that path for now.

Another question that I still haven't researched: if your materials are exempt....such as it's literally cotton and nothing else (like that would ever happen), do you have to still put a label on it saying it's exempt (and without need for testing).

I would assume so, but I need to do some serious reading. And by exempt, I mean something different than "compliant" (not exempt but has been tested, so therefore it's okay). Those 2 are different concepts under the law, right?

[Former_Member]

Hopefully they will work out and let you be able to make them. I know joanns sell the onesies and also the transfers to go with them.

[Former_Member]

Fingers crossed....which have been crossed so long about this that they're almost starting to bleed. :)

[Former_Member]

thanks for all the chattin' on this topic, guys! i'll let ya know what i hear... hopefully soon!

[Former_Member]

ok guys i got some answers, and sorry to say until the law allows component testing i can't justify the expense involved in offering just a few onesies and tees for kids in my shop.

twitter user @whimsicalwalney was awesome enough to take the time to share her cpsia knowledge since i couldn't make heads or tales of what i was reading, here's my emails with her answers i received this weekend

*****

i'm hoping in your extensive knowledge of the CPSIA that you can help me figure out a couple of things - i just need straight answers and i'm getting send to websites to read up on this, but i can't understand what i'm reading. what i really need is someone to help me understand. so here goes:

i currently sell screenprinted underwear and people & dog tees on my site and etsy. i'd like to expand into kids tees and onesies. my questions:

1) if i use american apparel organic blanks and yudu brand non-toxic screenprinting inks do i need to test my items? i think i read screenprinting ink is not exempt from testing but i don't know what that means. do i need to get certification from the ink manufacturer that it is lead free?

WW – Yes, you need to test your items because the screen printing inks are not part of the exemptions. The organic cotton is exempt (but if it’s an onesie, the snaps are not exempt so you must test). At this time, component testing (which would allow you to use the manufacturer’s certification) has not been approved but many people believe it will be in the next month or so. Until such time that component testing is approved you are responsible for having the tests conducted on your items and be able to show those certifications starting in Feb 2010. Many retailers are already asking for the certifications, however, so if you’re hoping to do wholesale selling you may have to test earlier than you’d like.

2) do i need to have an instance of the finished product tested? do i have to have every possible ink color and every possible organic onesie color i'd wanna use tested?

WW – Not only do the variations have to be tested, but so does each “batch” which is what is causing a headache for so many people. Yes, the finished product (at this time) needs to be tested. Again, if component testing is approved you will be able to use the upstream certifications (American Apparel’s & the ink manu’s).



If you have your design printed on a red t-shirt with white ink and a blue t-shirt with red ink both need to be tested. And the list goes on the more variety you want to offer. If you were to buy several dozen of one color of onesies you could probably call that a “batch” and worry only about selecting one of those for testing. Once you make another order however, it might be considered a new “batch” and then you’d have to test again. Yes, it’s a headache and the CPSC surely hasn’t provided enough guidance because they never took small batch manufacturers into account. This is another reason why so many are fighting for component testing – it would save the little guys (of which I used to be one) the hassle.

3) do i need to add a label and if so can you point me in the right direction as to what info needs to go on that?

WW- Yes, every item has to have a label if it is intended for a child under 12. I recommend these posts to get a better understanding:

1. http://www.whatisthecpsia.com/?p=446

2. http://www.whatisthecpsia.com/?p=563


4) what kind of testing is needed - what's it called and where can i get it done?

WW- I’m not quite sure where to start with this one. If component testing is approved, you shouldn’t have to worry about outside of ensuring your manufacturers have tested properly and that you can get the certifications from them. Many people are waiting to see what happens before worrying about getting their products tested while others used the XRF (x-ray scanner) to get the necessary results for now.

Come Feb 2010 the XRF reports won’t be valid unless several things in the law change: component testing (good for small manus) or XRF as alternative for small manus (also good). If neither of these things happen, then everyone is still on the hook for third party testing (gulp) which would mean costs like these: http://learningresourcesinc.blogspot.com/2009/10/cpsia-tenenbaum-doesnt-know-what.html depending on what you produce.

Should you need to test, you will want to find companies that do lead testing and if you’re doing screen printed bibs you’ll also need to find a lab that does phthalate testing. There are some labs on Twitter who have been joining the conversation once in a while so put a tweet out there if you’re in search of one. You can also talk to @thesmartmama if you just want basic XRF testing as she does that as well as give counsel to people (she’s a lawyer) about the law.

*****

so basically, the two onesies i screenprinted a few weeks ago won't see my etsy shop until component testing is allowed or i have kids, whichever comes first. and kids clothes from hearts and laserbeams is dead in the water for now. i declare shenanigans on the CPSIA!

steph

[Former_Member]

also i need to add that she specifically says in her email (in a part i didn't cut and paste, whoops!) that SHE IS NOT A LAWYER and her advice can not be considered official legal counsel. fyi be advised!

[Former_Member]

marking

[jerise]

homemade inks for screenprinting thread:
http://www.t-shirtforums.com/screen-printing/t47490.html

[Former_Member]

I work for an apparel mfg, and am actually a designer of licensed childrens screenprinted product. We do well over 90 million dozen garments a year, selling tens of thousands of a single design, and the testing is a pain for us!

I cant imagine what it would be like for a small shop.

One note - make sure that your waterbase inks are phtalate free - we had to switch ours over last year to be compliant. Imagine doing that in 20 different countries...still having nightmares.

[PattonHouse]

So I won't be making kids' clothes any time soon. Is it going to get to the point that the only options for buying clothes for my kid will be from mass retailers who can afford the testing - Target, Gap, etc.? Handmade or small-batch kids' clothes just don't seem like a viable option for anyone. Sad.

I know, I'm late to the train station on this one.

[Former_Member]

Southern - it's really sad! We are being legislated out of our entrepreneurial spirit!

People need to make a stink about this stuff! Im all for child safety, but sometimes its overkill.

We will be wrapping our little ones up in cotton batting before long. Unbleached, organic, cotton, of course.

[PattonHouse]

How far off base would it be to say the entire children's section of Etsy will disappear in 2010?

[Former_Member]

If I am understanding the law correctly, I can't sell my embellished jeans after Feb 2010. I just add cuffs or ruffles at the hem and sometimes an applique, but I would have to test the item since it is made with zippers and snaps, even though it would have already been tested by whomever I purchased the jeans. Yikes.

Southern, like many I am moving to all exempt items and hoping they stay exempt. But I'm not hopeful. :(

It isn't about child safety, it can't be. Because those same buttons, zippers and snaps that are too dangerous for us to use without testing, can be bought (untested, and with no labels warning of the dangers) in fabric stores everywhere ready to sew on childrens' apparel and toys.

[Former_Member]

fancyfrockslv says:

It isn't about child safety, it can't be. Because those same buttons, zippers and snaps that are too dangerous for us to use without testing, can be bought (untested, and with no labels warning of the dangers) in fabric stores everywhere ready to sew on childrens' apparel and toys.

--------------

Im trying really hard not to see some Marxist govt conspiracy to put an end to small enterprise, but legislation like this makes you wonder.

It isnt especially nice for the big boys either (my day job is for one of those).

Strangling taxation, testing costs, fines if you make a mistake, legal costs for filing...ugh.

Does congress get it??? Or are they so far removed from reality...wait...nevermind.

[OxtonBooks]

marking

[Former_Member]

The answer is and always will be yes. Certain exemptions under NAFTA and canadian certifications allow me to offer some children's clothing although not alot. If you use commercial products such as Speedball or Aqua you can contact those companies directly to ascertain what they have done to get on the exemption lists.

We cannot use our Eco-dyes even though they are 100% natural without testing. It is the process you would have to have the place that makes them (for me Custom Colour) to be certified.

The small vendor and childrens clothing is going to be a thing of the past.

[Former_Member]

this whole thread just made my heart sink a little...i only sew my fabric onto onesies right now...but wanted to venture into the screenprinting too.

Can i assume that if i get my stuff screenprinted elsewhere, that THEY are certified? I guess i'd have to ask. But this is terrible...looks like i should try to unload my inventory before 2010