CPSIA compliance - what have we learned thus far?

[Ripcord]

I've researched the (relatively) new regulations as much as possible and this is what I gather from everything I've read:

All products intended for use by children 12 and under must have a tracking label with the manufacturer, location (I use my zip code), phone number, date of manufacture, and lot number. That part is pretty clear...The part I think is still a little vague is the phthalate (sp?) restrictions

From what I've read and learned on the forums, products intended for use in play by children 12 and under must be free of phthalates, and also products for children under the age of 3 must be phtalate free if they are intended to facilitate eating or sleeping.

Clothing, as far as I can gather, is not intended to use for play unless it is a toy costume. Bibs and sleepwear are intended to facilitate eating or sleeping, but a T-shirt or hoody is not.

Does anyone have any more insight into this? It would be very helpful if the government would clarify exactly what is regulated and what isn't...The way the law is written it seems open to quite a bit of speculation.

[blue moon]

We actually have a section dedicated to the CPSIA stuff and had a good discussion there recently with a link pointing to some more info an T-Shirt forums.

quick recap:
-all 12 and under have to have a recall label
-all 12 and under have to be lead free and accompanied by a certificate of compliance. If under 1MM in sales or 7500 pieces, you can obtain exemption from testing, but still have to issue the paperwork with your axemption number (there is a little more to this, but this applies to most)
-all 3 and under if used for eating or sleeping have to be phthalate free

pierre

[Ripcord]

We actually have a section dedicated to the CPSIA stuff and had a good discussion there recently with a link pointing to some more info an T-Shirt forums.

quick recap:
-all 12 and under have to have a recall label
-all 12 and under have to be lead free and accompanied by a certificate of compliance. If under 1MM in sales or 7500 pieces, you can obtain exemption from testing, but still have to issue the paperwork with your axemption number (there is a little more to this, but this applies to most)
-all 3 and under if used for eating or sleeping have to be phthalate free

pierre

You're right, I posted this in the wrong category  (I didn't scroll down far enough...) The part I don't like is the eating and sleeping. They are rather vague about it. I know the concern is that if the product is intended to go into a kid's mouth, like a pacifier, it falls under the regulation. A bib is specifically mentioned as being for eating...But what if someone gets a cute T-shirt that he intends to use for his kid's pajamas? Does that mean it's intended for sleeping? And is the deciscion made arbitrarily by some beaurocrat?

[blue moon]

We actually have a section dedicated to the CPSIA stuff and had a good discussion there recently with a link pointing to some more info an T-Shirt forums.

quick recap:
-all 12 and under have to have a recall label
-all 12 and under have to be lead free and accompanied by a certificate of compliance. If under 1MM in sales or 7500 pieces, you can obtain exemption from testing, but still have to issue the paperwork with your axemption number (there is a little more to this, but this applies to most)
-all 3 and under if used for eating or sleeping have to be phthalate free

pierre

You're right, I posted this in the wrong category  (I didn't scroll down far enough...) The part I don't like is the eating and sleeping. They are rather vague about it. I know the concern is that if the product is intended to go into a kid's mouth, like a pacifier, it falls under the regulation. A bib is specifically mentioned as being for eating...But what if someone gets a cute T-shirt that he intends to use for his kid's pajamas? Does that mean it's intended for sleeping? And is the deciscion made arbitrarily by some beaurocrat?

from what I understand, it is based on the items intent and marketing. So an adult shirt marketed to adults does not need to comply just because your kid is sleeping in it. I would imagine the same to apply to the toddler shirts. Onesies are supposedly considered sleepwear, but I am not sure.

pierre

[Ripcord]

from what I understand, it is based on the items intent and marketing. So an adult shirt marketed to adults does not need to comply just because your kid is sleeping in it. I would imagine the same to apply to the toddler shirts. Onesies are supposedly considered sleepwear, but I am not sure.

pierre

I had an idea that I think I'm going to start doing for toddler and infant shirts. On the recall label I'm going to add a second line that says "This item is not intended to be used for eating or sleeping."

[Denis Kolar]

For example, I produce a shirt in size kids 2-4 and place it on the web for sale.
As long as put on it that it is not intended for sleeping and eating in it, I should be fine then.

[Denis Kolar]

Man, you got me to it first

[blue moon]

from what I understand, it is based on the items intent and marketing. So an adult shirt marketed to adults does not need to comply just because your kid is sleeping in it. I would imagine the same to apply to the toddler shirts. Onesies are supposedly considered sleepwear, but I am not sure.

pierre

I had an idea that I think I'm going to start doing for toddler and infant shirts. On the recall label I'm going to add a second line that says "This item is not intended to be used for eating or sleeping."

that SHOULD get you off the hook for the phthalates. You are still responsible for the lead conformity certificate though.

pierre

[Frog]

Unless someone decides that it is not reasonable to expect a need to change your toddler six times a day whenever he or she may eat something or doze off.

Perhaps there is a lawyer for one of the industry groups who could address this.