CPSIA – What Children’s Clothing Designers and Manufacturers Need to Know





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:


National Bankruptcy Day

CPSIA Central Forum

Boutique Cafe

Apparel Search

The Smart Mama


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

Corky & Company’s Letter to Congress in Support for NAM Petition

Z Recommends post about CPSC’s Request for Comments

The Stitchery post on NAM’s Petition

Other things you can do:

Email Congress (easy form sent directly to your representatives)

Sign the Petition

Vote to make this issue a priority to the President

Listen to Mark Riffey’s Business is Personal CPSIA Broadcast

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.

With friendship,

Lisa Carroccio


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.)



  1. Do you think that the government is interested in hearing from consumers? I just make clothes for my kids and myself, but I think that this kind of regulation is ridiculous!

  2. Hi Lisa, our new folder on the forum is ready. The folder is to discuss what we should submit in response to the CPSC’s list of eight questions. http://tinyurl.com/8xsolf

    Please spread the word.

  3. Great post with lots of info – thanks Lisa!!

  4. Lisa,

    Very well written article about this heinous work of legislation. I’m spreading the word as best I know how and just hope our voices will be heard. If I receive another form letter from a legislator of the CPSC that does not address my concerns I will scream.

    Good luck with your new line. I think it’s truly fabulous!


  5. Well HELLO, the food wholesale/retail industry already has to do stuff like this….ever hear of COOL country of origin labeling? huge fines for non compliance. and as also in the food growing industry has to maintian indescrable records of every morsel that is produced in the usa. what chemical/fertilizers non organic and organic were used, and the weather at the time. and whether or not the outhouse has toilet paper. well actually that is another set of regulations.

    I sure hear you!!!!!!!!!!!!!!!!!!!!!!!!!!don’t get me started ;(

    friendship back to you Lisa, and thanks for keeping us updated on marielle. Merry Christmas to you all.

  6. Thank you so much for summing this up so succinctly. Every time I think I have a handle on it I get more info overload – but this is much tidier than the mess of mental stickies in my brain!

  7. I have a question.

    THere are several consignment stores in my area that have no idea about this.
    Can someone tell me how this will effect them.

    THey take clothes & toys in from people. sell them & split what they are sold for.

    I am assuming by what I have read that they will no longer be abe to do this?

    If that is the case…I wonder why they dont know, & when they will find out?

    If someone culd help me with these answers that would be great.

    Also, can someone tell me if diaper bags are a part of this.
    They are for babies, but MOMS use them????

  8. We DO NOT want this to happen! Toys YES! Clothing NO!

  9. Lisa,
    Excellent post!! I’m going to link to you from my own blog, if you don’t mind. Don’t think any of us could’ve wrapped it up better. I appreciate all your helpful, included links.

  10. Lisa,
    Great job explaining everything!! I have been busy letting everyone know about this and now to have a location that sums it up in easy to understand terms is wonderful!

    I have personally contacted everyone who has the ability to make a change to this law for all of us. . . not only have I done the emails, I have actually called and talked to them individually.

    Right now, all I can do for my business, is ask for a waiver or an exception. Since they are done on an individual basis, each of you will need to do the same. I have let them know they just put me out of business unless a waiver or a major change to the law occurs. I am waiting for their answer.

    Don’t give up!! If all of us show up at the welfare office on Feb 10th out of work, needing assistance. . . I think there would be action immediately.

    Keep fighting for your rights and I will do the same!

  11. Kathy Schetterer says:

    I’m JUST a micro, micro,maufacturer, This new lead testing law for kids clothes has to be the most rediculous law ever passed
    by CONGRESS. I was under the impression we have smart country leaders,well, I’m wrong again.
    Thrift shops and consignment shops have been excluded from the lead testing law. What a DOUBLE STANDARD.This will not
    bode well.

  12. Lisa,

    Thank you for your information. I am a manufacture of organic clothing in China and use only dyes compliant with oeko-tex standards that are made in Switzerland, yet I am completely stunned at this new requirement.

    My client will not pay this fee nor can I.

    Who’s responsibility is it for having the garments I manufacture/import inspected? Me or my client/clients?

    Please help me understand and clarify as I am unclear and need to instruct my manufacture and client

    Thank you

  13. There are 23 licened testing facilities listed on the government site not that that makes any difference. Just thought you might want to know.


  14. Hello there! I just want to offer you a big thumbs up for your great information you’ve got right here on this post. I’ll be coming back to your web site for more soon.

  15. Hi there! Any update on this issue?


  1. […] passed. I’m incredibly stunned at the short-sightedness of the people who wrote & passed this thing. The repercussions to the second-hand and indie markets are…unspeakable. I’m too […]

  2. […] Domestic Diva, who also has a children’s clothing company, did an awesome job of listing out all the people she could think of who would be effected by this law, within our industry (see thumbnail to the right of said impressive list). It’s long. And this is just within the clothing business! Her post is a great overall, too & was one of the first that really got me to wake up & take action. Plus, she continues to put her heart & soul into keeping us all up to date. Thanks Lisa! […]

  3. […] CPSIA – What Children’s Clothing Designers and Manufacturers Need to Know I dont know the answer to you specific question but this above law is intended to protect kids […]

  4. […] Domestic Diva, who also has a children’s clothing company, did an awesome job of listing out all the people she could think of who would be effected by this law, within our industry (see thumbnail to the right of said impressive list). It’s long. And this is just within the clothing business! Her post is a great overall, too & was one of the first that really got me to wake up & take action. Plus, she continues to put her heart & soul into keeping us all up to date. Thanks Lisa! […]

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