Consumer Product Safety Improvement Act (CPSIA) and your needlework business.

You are probably aware that there are new rules relating to lead in children's products.

Contrary to what you may have heard, these new rules will have little effect on retail needlework stores. The Consumer Product Safety Commission (CPSC) has done a very good job of establishing reasonable guidelines that will protect children without creating unnecessary hardship for most businesses.

I encourage you to ignore the dire predictions that you may have heard. Instead, get the real facts directly from the Consumer Product Safety Commission web site.

The Guide to the Consumer Product Safety Improvement Act (CPSIA) for Small Businesses, Resellers, Crafters and Charities from the CPSC web site does an excellent job of explaining how the new rules apply to small businesses. Read this page first. This link is sometimes slow to open. Here is a copy.

Guidance for Small Manufacturers, Importers, and Crafters of Children’s Products

CPSIA general information page on the Consumer Product Safety Commission site.

 

Here are the highlights that would apply to a retail needlework store.

The new rules apply to children's products. A children's product is one designed or intended primarily for children 12 years of age or younger.

• Wood and other natural materials including coral, amber, feathers, fur, and untreated leather.
• Yarn, dyed or undyed.
• Dyed or undyed textiles (cotton, wool, hemp, nylon, etc.), including children's fabric products, such as baby blankets, and non-metallic thread and trim. This does not include products that have rhinestones or other ornaments that may contain lead or that have fasteners with possible lead content (such as buttons, metal snaps, zippers or grommets).
• Children's books printed after 1985 that are conventionally printed and intended to be read, as opposed to used for play.
• Surgical steel. Gold, of at least 10 karats. Silver, at least 925/1000 pure. Platinum, palladium, rhodium, osmium, iridium, and ruthenium.

You or your customers can make and donate children's products to local charities and hospitals, if they are made of exempted materials or materials that you feel confident do not contain lead (see above). Children's products made of yarn, dyed or undyed fabrics, and natural materials such as untreated wood or cotton do not contain lead at levels sufficient to exceed the new lead limits.

Resellers and retailers of children's products are not required to do testing. The testing requirements apply to manufacturers and importers. However, retailers and resellers cannot knowingly sell children's products that do not meet the requirements of the law. It is against the law to sell a recalled product. You can check for recalled children's products on the CPSC web site

Component Parts.

As mentioned earlier, the rules have not been finalized. One area yet to be resolved that will effect manufacturers in our industry is the testing of component parts. Under current rules a manufacturer is required to test  their product in its final state (if testing is required). That is, a company that manufactures baby bibs with a zipper or snap must have the entire final baby bib tested for lead.

The CPSC is looking at allowing third-party testing of component parts. If approved, this could allow testing of the individual components to be tested, and not the final product. If approved, a company that makes baby bibs may not be required to test the final product if all the component parts have been tested by the manufacturers of the various component parts.

Here is the CPSC request for public input on third-party testing. The deadline for public input has passed (January 30, 2009). Guidelines have not yet been issued.

This information is current as of June, 2009.