CPSIA seminar on SGIA. Did anybody listen to it and a quick recap.

[blue moon]

Here's what I think is going on:

essentially, items for kids 12 and under will have to have a certificate accompanying the product.

-Small companies will be able to get a testing exemption number and use it in the certificate, but one will have to be generated for each product. So the certificate will state that you are exempt from testing, it will describe the product and it will list your exemption number (not sure who issues those so I'll have to track it down. I think there will be a link to it on the SGIA and possibly CPSIA site).
- If doing more than $1MM in sales or producing more than 7K items, the certificate will have to contain the testing results.
-Testing results can be provided by component manufacturers (think zippers, buttons, inks, laces and so on . . .). Then the certificate would list all the individual components on it.
-Each individual item can be tested and the results can be included in the certificate.

few extra tidbits:
-shirts do not have to be tested.
-inks do (but it is still uncertain if they are to be treated as paint or component which require two different types of testing.
-feeding and care articles for babies (3 and younger) also have to have a Phthalate compliance certificate.
-certificates do not have to be signed in person (electronically generated certificates are OK)
-stay on testing expires at the end of this year and thus starting 01/01/12 decorated garments for 12 and under have to be certified.
-the tracking label requirements are still in effect and all items for 12 and younger should have them.
-component manufacturers (ink for example) are not required to test!!! And this is where it becomes interesting. If your ink manufacturer is not testing, but another on is, do you switch? The test are supposed to be in the $50-$350 range and have to be done for each batch. In other words, if you have a bucket of white and run out, the next one will have to be tested before it can be used on the children's product. There might be an opportunity for distributors to buy a batch of ink and have it tested, but that is a whole different conversation . . .

FYI there is a brief discussion going on at the t-shirtforums with few other thoughts.


pierre

[blue moon]

here is the link to the tread on the T-shirtforum:

http://www.t-shirtforums.com/screen-printing/t172619.html

pierre

[Gabe]

no thanks i am loyal to frog

[Frog]

Well hell, I'm reading it!

[Homer]

color me stupid -but- what issue is this "law" trying to solve? it still seems very grey, no definite answers.

I noticed a few guys said they don't print youth items anymore, how would you prove that? an adult small could fit a 10 year old, so by showing packing lists won't work. . .

[Frog]

color me stupid -but- what issue is this "law" trying to solve? it still seems very grey, no definite answers.

I noticed a few guys said they don't print youth items anymore, how would you prove that? an adult small could fit a 10 year old, so by showing packing lists won't work. . .

That is generally one of the least confusing parts. It is aimed at goods designed for and primarily used by kids.

Barbie Make-up - yes
Mom's Maybeline makeup that a kid gets into - No

Adult small T's that say Joe's Preschool - probably not
Adult small T's that say Joe's Preschool but are designed as coveralls for arts and crafts - Now you have it a little grayer, and would be better off not knowing the ultimate purpose.

[blue moon]

color me stupid -but- what issue is this "law" trying to solve? it still seems very grey, no definite answers.

I noticed a few guys said they don't print youth items anymore, how would you prove that? an adult small could fit a 10 year old, so by showing packing lists won't work. . .

As Frog said, this one is easy. The marketing is the benchmark. If it is marketed to kids, it has to be certified. Any products for adults that kids have access to or might use are still adult products and do not have to be compliant.

Age cut off is 12 for lead and 3 for phthalates.

pierre

[tpitman]

Ultimately, most printers will probably ignore the "rules" and print whatever the customer wants. The customer isn't going to care whether or not the ink you slap on their brat's shirt is "compliant" with some arcane law. All they care about is how much the shirt costs. It's not as if we've been selling shirts soaked in gasoline all along, and suddenly the word is out that it's dangerous for toddlers . . .
For those who plan on following the letter of the law, do you think your customer is going to gratefully pay any additional labor costs you incur for keeping all this crap sorted out, or do you plan on eating the extra labor yourself just to stay competitive? When you lay the price on them, and explain the details, what are the chances that they're gonna ask "Gary Garage Printer" if his shirts are compliant when he beats you up on price?
And when push comes to shove, who in the gubmint is gonna monitor every podunk print shop to see if you've got testing results for the 24 shirts you may or may not have printed for some mom? They can't get you on all t-shirts, just youth t-shirts. Maybe the wholesalers will be forced to rat us out everytime we place an order that includes a few youth sizes.
Yup, nothing wrong with this country that a little more regulation won't fix because the sheep that comprise the t-shirt buying public have been putting their offspring in the dangerously poisonous clothing greedy screenprinters have been hustling for decades . . .

There's something wrong with a law that requires two webinars for someone who's actually up on this to explain it, and still leave lots of people seemingly confused about what gets tested by these third-party labs, and to whom the responsibility falls, and how compliance will be enforced. Why don't they just say shirts are exempt, every batch of ink/zippers/rhinestones/ heat press material has to be tested by the manufacturer before distribution, and no modification can be made to any product after testing? Then we can choose to comply, cheat, or not print that crap. I guess they had to "pass it so we could find out what was in it", but that's what my doctor tells me when he asks for a stool sample.

[blue moon]

Ultimately, most printers will probably ignore the "rules" and print whatever the customer wants. The customer isn't going to care whether or not the ink you slap on their brat's shirt is "compliant" with some arcane law. All they care about is how much the shirt costs. It's not as if we've been selling shirts soaked in gasoline all along, and suddenly the word is out that it's dangerous for toddlers . . .
For those who plan on following the letter of the law, do you think your customer is going to gratefully pay any additional labor costs you incur for keeping all this crap sorted out, or do you plan on eating the extra labor yourself just to stay competitive? When you lay the price on them, and explain the details, what are the chances that they're gonna ask "Gary Garage Printer" if his shirts are compliant when he beats you up on price?
And when push comes to shove, who in the gubmint is gonna monitor every podunk print shop to see if you've got testing results for the 24 shirts you may or may not have printed for some mom? They can't get you on all t-shirts, just youth t-shirts. Maybe the wholesalers will be forced to rat us out everytime we place an order that includes a few youth sizes.
Yup, nothing wrong with this country that a little more regulation won't fix because the sheep that comprise the t-shirt buying public have been putting their offspring in the dangerously poisonous clothing greedy screenprinters have been hustling for decades . . .

There's something wrong with a law that requires two webinars for someone who's actually up on this to explain it, and still leave lots of people seemingly confused about what gets tested by these third-party labs, and to whom the responsibility falls, and how compliance will be enforced. Why don't they just say shirts are exempt, every batch of ink/zippers/rhinestones/ heat press material has to be tested by the manufacturer before distribution, and no modification can be made to any product after testing? Then we can choose to comply, cheat, or not print that crap. I guess they had to "pass it so we could find out what was in it", but that's what my doctor tells me when he asks for a stool sample.

I think there is a good marketing ploy to be had out of this. For smaller companies it will take a few hours of work to get the exemption paperwork, but then you can be legal and still print with the same inks you use now. The only difference will be having to create a certificate with every order. If done right, it should not take more than a min of your time. Now you can market your services as being compliant unlike the garage printer that is undercutting your prices. It also portrays your business as somebody who is on top of things and many ppl are  more likely to pay a little bit extra for it. Not everybody will, but in my book, those are the customers we want.

Here's something else to think about. When you are pitching a bid to the school or organization, you can list your product as CPSIA compliant. Can the other printers do the same? You can offer two versions, one with tracking numbers and certificates and another at a discounted price without them and a five page document having them assume all liability for failure to comply with the regulations. Watch them dump the rest and give you the bid at a higher price!

For few hours that will it will take to get that paperwork in order, it has huge upside!


pierre

[Frog]

Ultimately, most printers will probably ignore the "rules" and print whatever the customer wants. The customer isn't going to care whether or not the ink you slap on their brat's shirt is "compliant" with some arcane law. All they care about is how much the shirt costs. It's not as if we've been selling shirts soaked in gasoline all along, and suddenly the word is out that it's dangerous for toddlers . . .
For those who plan on following the letter of the law, do you think your customer is going to gratefully pay any additional labor costs you incur for keeping all this crap sorted out, or do you plan on eating the extra labor yourself just to stay competitive? When you lay the price on them, and explain the details, what are the chances that they're gonna ask "Gary Garage Printer" if his shirts are compliant when he beats you up on price?
And when push comes to shove, who in the gubmint is gonna monitor every podunk print shop to see if you've got testing results for the 24 shirts you may or may not have printed for some mom? They can't get you on all t-shirts, just youth t-shirts. Maybe the wholesalers will be forced to rat us out everytime we place an order that includes a few youth sizes.
Yup, nothing wrong with this country that a little more regulation won't fix because the sheep that comprise the t-shirt buying public have been putting their offspring in the dangerously poisonous clothing greedy screenprinters have been hustling for decades . . .

There's something wrong with a law that requires two webinars for someone who's actually up on this to explain it, and still leave lots of people seemingly confused about what gets tested by these third-party labs, and to whom the responsibility falls, and how compliance will be enforced. Why don't they just say shirts are exempt, every batch of ink/zippers/rhinestones/ heat press material has to be tested by the manufacturer before distribution, and no modification can be made to any product after testing? Then we can choose to comply, cheat, or not print that crap. I guess they had to "pass it so we could find out what was in it", but that's what my doctor tells me when he asks for a stool sample.

I think there is a good marketing ploy to be had out of this. For smaller companies it will take a few hours of work to get the exemption paperwork, but then you can be legal and still print with the same inks you use now. The only difference will be having to create a certificate with every order. If done right, it should not take more than a min of your time. Now you can market your services as being compliant unlike the garage printer that is undercutting your prices. It also portrays your business as somebody who is on top of things and many ppl are  more likely to pay a little bit extra for it. Not everybody will, but in my book, those are the customers we want.

Here's something else to think about. When you are pitching a bid to the school or organization, you can list your product as CPSIA compliant. Can the other printers do the same? You can offer two versions, one with tracking numbers and certificates and another at a discounted price without them and a five page document having them assume all liability for failure to comply with the regulations. Watch them dump the rest and give you the bid at a higher price!

For few hours that will it will take to get that paperwork in order, it has huge upside!


pierre

I can also see printers who do very little youth work, to now just pass on it, opening up more work for those who do.

[blue moon]

and to be fair I should put out a DISCLAIMER that I am working on another company that will provide various services to the printers (including tracking and certification compliance). The tracking part is done and we have been alpha testing if for a few months now. The beta is written, but not out yet. We will add the compliance/certificate part next. The goal will be to auto generate the certificate from the tracking information entered.

pierre

[Doug B]

  This is what I send to every customer buying youth goods
It only takes a second to change the dates, batch#, etc.

[blue moon]

  This is what I send to every customer buying youth goods
It only takes a second to change the dates, batch#, etc.

from what I understand, there are two issues you are trying to address.
1. recall info. by creating a tracking number and documenting all the inks, you are almost there.
What also needs to be included is the lot numbers for the garments and then they have to be marked with that info (or it has to be ascertainable from the info on the shirt). You could place your phone number or a web site so they can call you and get those details from you.
To meet the rest of the requirements, you have to be able to contact the customer who bought a recalled garment (or ink) in case manufacturer notifies you that it has been recalled (so if Gildan issues a recall notice for a particular lot, you have to be able to contact your customers that purchased those particular shirts.
2. lead and phthalate compliance. General conformity certificate or MSDS sheets do not meet the legal requirements. The components have to be tested by a certified lab. Just stating that they do not use lead in the ink is not enough, it actually has to be proved. (unless you have the exemption number issued to you)

there is one more detail here. If the item has to be tested for any other reason, the exemption does not apply any more. So if it has to be tested for fire resistance or anything else, ink has to be tested too.

pierre

[Doug B]

  I also print a tag on the inside back of the shirt with the date, tracking number
our name and our 800 number.   

[blue moon]

  I also print a tag on the inside back of the shirt with the date, tracking number
our name and our 800 number.   

that makes you Section 103 compliant (from what I can tell)! Which is more than rest of us have going for us.

the lead and phthalate testing part is covered by the Section 102.

pierre