where can I find info about this new labeling going into effect in August?

[Former_Member]

I'm a little confused about this. Anyone have a link? Thanks.

[Former_Member]

http://www.cpsc.gov/ABOUT/Cpsia/summaries/103brief.html
hope this helps you :)

[Former_Member]

PrideSpiritCreations Thank you for info as well. I just started a childrens line of jewelry and I havn't even heard of this law yet. Good question!

[bobbinalong]

I may be wrong, but I think this labeling stuff could change ten times before August. That is the whole problem with the CPSIA. It was written with wiggle room for the CPSC. So while here in April, we think we might know what should be on the tracking label, by August, it may have changed. I make booties with no seams. How in the world do I put on or in a tracking label? Wouldn't that be uncomfortable for a baby? The CPSC needs to think some things through.

[Former_Member]

Remember in August not only does the label requirement come into effect but so does the yet lower lead limit of 300 ppm for all children's product and 90 ppm for kids products with paint or stains. So even with the COCs, COAs, or COGs from your raw supply manufactures you may yet need additional information that gives the exact lead and phthalate content of your materials. In other words what supplies you have right may be OK, for right now, but may be over the limits come Aug. See TABLE A here, http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q4 for what needs testing now & what you can still sell using the raw material manufacturer's testing certifications until Feb 2010 or the appointment of a new chairperson.
Unfortunately there are still no guidance on how to permanently label any piece of children's jewelry or other small child's product, like booties, with all the information the the law requires. Also way back when the CPSIA first popped up in the forum there was a link to a blog where someone failed testing solely on the fact that the wrong font and color was used on their product's warning label about choking hazards. I can believe that the CPSC will be just as stringent on how the product labels are worded and how small the wording is. There is a "where practical" clause to the law concerning labeling, but I feel eventually when this law is known by a larger audience that customers are going to be asking for the where's the info regardless of the size of the product they purchase.



Jewelry Designers should be aware that jewelry the government feels is primarily for children 12 & UNDER is required to undergo mandatory 3rd PARTY TESTING under the CPSIA for children's jewelry as of MARCH 20th, 2009.
There have been updates and proposed exemptions, but they are not final, I suggest that you check Table B here fequently http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q8 since it may change suddenly if Nord steps down as acting chairperson of the CPSC.
As of right now if your items are made exclusively of exempt materials currently you will not need to retest the finished jewelry for lead, though you might need the small parts testing or warnings dependant on what age the jewelry is considered for. But once you add a single component that is not on the list then the entire piece will have to be tested by a CPSC approved lab. So Sterling Silver clasp + SS crimps + silk threading + natural freshwater pearls are OK to skip the lead testing but not the small parts testing (if needed), but Sterling Silver clasp + SS crimps + silk threading + natural freshwater pearls + E6000 glue would need testing for lead as well as the small parts testing (if needed), & the only thing that changed is glue was added to reinforce the knot on the silk. Again there is no clarification if any enchanced form of a natural bead will fall into the exempt item list at all, at least until there is a final ruling that has more details.

There are 34 labs listed as being here in the USA out of the 133 total, but not all of the labs can test jewelry, and all of those that can test jewelry may not be accredited to do the small parts testing if needed. Also the only approved testing method for jewelry is destructive digestive acid testing, in which they pull apart the final creative piece and bath each component in acid to see how much lead is there in each component by weight. All you get back is a report, and a bill for testing at around $75 -$100 per component, so using the example above with glue your testing bill would be $375 -$500 for lead testing alone. See the list of accredited labs here http://www.cpsc.gov/cgi-bin/labapplist.aspx .

[Former_Member]

Remember in August not only does the label requirement come into effect but so does the yet lower lead limit of 300 ppm for all children's product and 90 ppm for kids products with paint or stains. So even with the COCs, COAs, or COGs from your raw supply manufactures you may yet need additional information that gives the exact lead and phthalate content of your materials. In other words what supplies you have right may be OK, for right now, but may be over the limits come Aug. See TABLE A here, http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q4 for what needs testing now & what you can still sell using the raw material manufacturer's testing certifications until Feb 2010 or the appointment of a new chairperson.
Unfortunately there are still no guidance on how to permanently label any piece of children's jewelry or other small child's product, like booties, with all the information the the law requires. Also way back when the CPSIA first popped up in the forum there was a link to a blog where someone failed testing solely on the fact that the wrong font and color was used on their product's warning label about choking hazards. I can believe that the CPSC will be just as stringent on how the product labels are worded and how small the wording is. There is a "where practical" clause to the law concerning labeling, but I feel eventually when this law is known by a larger audience that customers are going to be asking for the where's the info regardless of the size of the product they purchase.



Jewelry Designers should be aware that jewelry the government feels is primarily for children 12 & UNDER is required to undergo mandatory 3rd PARTY TESTING under the CPSIA for children's jewelry as of MARCH 20th, 2009.
There have been updates and proposed exemptions, but they are not final, I suggest that you check Table B here fequently http://cpsc.gov/about/cpsia/smbus/manufacturers.html#q8 since it may change suddenly if Nord steps down as acting chairperson of the CPSC.
As of right now if your items are made exclusively of exempt materials currently you will not need to retest the finished jewelry for lead, though you might need the small parts testing or warnings dependant on what age the jewelry is considered for. But once you add a single component that is not on the list then the entire piece will have to be tested by a CPSC approved lab. So Sterling Silver clasp + SS crimps + silk threading + natural freshwater pearls are OK to skip the lead testing but not the small parts testing (if needed), but Sterling Silver clasp + SS crimps + silk threading + natural freshwater pearls + E6000 glue would need testing for lead as well as the small parts testing (if needed), & the only thing that changed is glue was added to reinforce the knot on the silk. Again there is no clarification if any enchanced form of a natural bead will fall into the exempt item list at all, at least until there is a final ruling that has more details.

There are 34 labs listed as being here in the USA out of the 133 total, but not all of the labs can test jewelry, and all of those that can test jewelry may not be accredited to do the small parts testing if needed. Also the only approved testing method for jewelry is destructive digestive acid testing, in which they pull apart the final creative piece and bath each component in acid to see how much lead is there in each component by weight. All you get back is a report, and a bill for testing at around $75 -$100 per component, so using the example above with glue your testing bill would be $375 -$500 for lead testing alone. See the list of accredited labs here http://www.cpsc.gov/cgi-bin/labapplist.aspx .

[Former_Member]

sheesh! I'm almost sorry I asked :) Thanks for the link PrideSpiritCreations. I wish there could be an example of what exactly they are looking for. Can I just print a tag and sew it into a garment? And then will the tag have to be tested for lead as well?

jewelrydesignsbyME, thanks for your info as well.

[OgsploshAccessories]

My kids are into Littlest Pet Shops. It will be interested to see how the manufacturers will get all that information on a tiny toy!
I have never come across such an ill thought out law.

[Former_Member]

I'm wondering how they will get that into tiny newborn socks?? I have some newborn anklet socks (super adorable) that are about the size of my thumb...okay they're smaller than that. Who wants to put a tag in one of those??

The only proactive thing I can do right now is to create an alternate line of items. I can't guess what they're going to do, but I have to plan now for my items.

[Former_Member]

marking ~thank you