SEE UPDATE AT THE END OF THIS POST
THIS IS IMPORTANT!
If you manufacture (design, sew, make, produce, create, paint, embellish, silkscreen, assemble, etc.) children’s products, this affects YOU!
As of February 10, 2009, you are required to produce a General Conformity Certificate (GCC) stating your products contain no more than 600 ppm lead.
As of August 14, 2009, you are required to have your products tested by a CPSC accredited lab stating your products contain no more than 300 ppm lead. In addition, all products must have permanent tracking labels.
The Consumer Product Safety Improvement Act itself: CPSIA
Here’s a great explanation of the new requirements: NSF.org
Even though the CPSIA affects everyone who makes products intended for children 12 and under, I’m going to focus primarily on children’s clothing manufacturing (because that’s what I do).
If children’s clothing manufacturers, big and small, go out of business, it will affect everyone. If a children’s clothing manufacturer closes their doors, they will no longer need:
- pattern makers
- sewing contractors
- embroidery companies
- fabric cutters
- retail children’s clothing boutiques
- retail customers (consumers)
- fabric suppliers
- children’s clothing sales representatives
- sewing machine manufacturers
- children’s clothing trade magazines
- children’s clothing trade shows
- web site designers
- graphic artists
- printers (posters, stationery, signs, etc.)
- in-house staff (secretary, bookkeeper, seamstress)
- sample makers
- advertising companies
- public relations firms
- hangtag suppliers
- garment care tag suppliers
- elastic manufacturers
- button manufacturer
- metal snap manufacturers
- thread manufacturers
- zipper manufacturers
- silk screen companies
- bias tape manufacturers
- paper packaging companies
- trade show display companies
- freight companies
- import/export agencies
- federal and state tax agencies
- federal and state licensing agencies
- and hundreds of others
Join the Fashion-Incubator CPSIA Forum (it’s FREE). Here’s where I get almost all my pertinent information about the new CPSIA regulations.
Sites focusing on this legislation and its ramifications:
In addition to lead testing, the CPSIA has new tracking label requirements. It is explained clearly over here at Fashion-Incubator. This new requirement would create a bookkeeping nightmare for many companies. It would add layers of paperwork to document and track each and every item produced–not to mention the cost involved with implementing and maintaining these records.
There are only
15 23 CPSC Accredited Testing Labs in the US who test for lab. Now would someone explain to me how 15 23 labs will be able to happen the amount of testing necessary to test ALL children’s clothing made here in the US by the deadline? What about all the other types of children’s manufacturers?
Then there is the issue of testing costs for lead. Let’s DO THE MATH. For my boys’ clothing line, testing would cost approximately $11,000 per season times 2 seasons (Spring/Summer and Fall/Winter) equals $22,000! As it stands now, the law requires children’s manufacturers to test finished batches of each SKU. It doesn’t matter that you use the same fabric, buttons or other component throughout your clothing line. If you are using the same fabric in 15 different styles, it still needs to be tested each time you manufacture a style, batch and different size. That is simply cost-prohibitive for most children’s clothing manufacturers.
If you need XRF testing, contact Jennifer Taggert, Attorney and Environmental Engineer at http://www.thesmartmama.com/bg/. Please note, XRF testing is only good for General Conformity Certificates (required February 10th). YOU MUST have certified lab testing done by August 12, 2009.
Because of the thousands of letters from those in the children’s industry, the CPSC has responded and asked for comments.
The most important thing you can do right now is answer the CPSC’s Request for Comments on Mandatory 3rd Party Testing by January 30, 2009! I encourage you to do this as soon as possible.
In response to the CPSC, the National Association of Manufacturers (NAM) CPSC Coalition sent the CPSC a Petition. This petition seems to cover all my concerns with the new legislation. NAM members include:
American Apparel & Footwear Association
Association of American Publishers
Book Manufacturers Institute, Inc.
Fashion Jewelry Trade Association
Juvenile Product Manufacturers Association
National Association of Manufacturers
National Association of Printing Ink Manufacturers
National Retail Federation
Retail Industry Leaders Association
Printing Industries of America
Specialty Graphic Imaging Association
Toy Industry Association
Other things you can do:
Email Congress (easy form sent directly to your representatives)
Let’s hope everyone in the industry finds a way to ensure child safety, yet make mandatory testing and labeling feasible for all children’s manufacturers.
UPDATE: The CPSC has issued exemptions for several types of material including UNDYED cotton, wool, silk, etc. Only problem is most children’s clothing manufacturers use dyed, embellished or otherwise processed fabric. So therefore, it really doesn’t help us. Stay tuned…I’m hopeful the CPSC will be updating us soon.
Disclaimer: All of the above post is opinion and not to be construed as legal advice. In these matters, please seek the services of a professional.)