Interesting situation - I think I'll be OK

[Ripcord]

I have a customer that is having a baby shower and came up with the idea of printing the invitations on bibs and mailing them to her friends. We all know the pthalate restrictions and contact label requirements for children under 3 (bibs are used for eating so are subject to the law).

I decided to do the job since these are not intended for actual use by babies, rather as a novelty for adults. I plan to print a disclaimer on the back making it clear that these are for the purpose of an invitation and are not intended for use by children under 3.

While the law is vague in some areas, it is clear that the regulation applies to products intended for use by children under 3. These clearly are not. I believe under the circumstances, and especially with the printed disclaimer, that this is OK to print. What do you guys think?

[ScreenFoo]

I makes me think of the guy on TSF who said he doesn't print for children, only adults and adult leprachauns....   

[Frog]

With the time and effort taken to print the disclaimer, myself, I'd rather opt to use acceptable inks and add a tracking label instead, even without the small user exemption or any other newly developed red tape, I feel that it shows an intent to comply that hopefully will count for something.
Pierre recently posted the information and his own experience on the exemption, so that is on my "to do" list.

Otherwise, your disclaimer might cover you in the end, and/or in fact, could serve as a lesson to us all if not

[Evo]

Print with wb inks? Better for bibs anyway.

[RICK STEFANICK]

I was thinking the same thing. or use that new rutland HSA.

[Ripcord]

Yeah, but this is one order of 35 bibs. I don't wanna buy special ink....

[Frog]

"Special" Ink doesn't relieve one of any of the other obligations under the law. It merely meets the requirements.

[blue moon]

as far as I understand, you do not have to print the disclaimer(the text of the invite will indicate the purpose). I would advise against printing the tracking info as it might be interpreted as child care article which it clearly isn't. Using phthalate free inks will not make you compliant. Using phthalate free ink in a shop that uses phthalates on regular bases might not pass the testing anyway (due to cross contamination from the squeegees, dryer fumes and other similar issues).

The yardstick for judging is the intent. This has nothing to do with kids so no CPSIA regulation applies.

Now, I am not a lawyer, but damn, if I haven't spent about a hundred hours researching this I have not spent a min. . .

pierre

[dsh]

Pierre,
Would sublimation avoid issues?  It would be pricey (amount of ink used) is they wanted a background color other than white, but you would bypass the whole phthalate issue.

[blue moon]

Pierre,
Would sublimation avoid issues?  It would be pricey (amount of ink used) is they wanted a background color other than white, but you would bypass the whole phthalate issue.

two issues we are talking about here, tracking and conformity. Both of those only apply to products for kids 12 and under so neither of them are in play in this particular case.

no need for special ink  or what not . . .

pierre