CPSC COMPLIANCE

 

What is the CPSC?

CPSC stands for the Consumer Product Safety Commission.  The Commission has lead requirements for all children's products, along with other more product specific requirements regarding components and labeling.  Third party testing is required unless you or the materials you use meet certain requirements, such as are set forth in the regulations and those set forth for Small Batch Manufacturers.  The CPSIA is the act that gave the CPSC more regulatory and enforcement tools, as well as adding to several statutes.  
 

Are you a Small Batch Manufacturer and what does that mean?

I have registered my business as a Small Batch Manufacturer.  This means that, depending on the products I make, I am exempt from certain third-party testing requirements.  However I must still certify that I take precautions to be compliant by ensuring that my children's products are made with compliant materials.  

 

More about testing requirements

Under CPSC regulations, natural fibers and items are exempt from testing for lead.  Extensive testing has revealed that the processes used for making textiles from these materials does not involve lead.  This means that the cotton materials I use do not require testing as the process to create them has been deemed safe.  Materials such as polyester and nylon have also been extensively tested and are on the exempt materials list.  

Snaps, zippers and eyelets have to be tested for lead, BPA and phthalate content (where applicable and depending upon use), if they are going to be used on a children's product.  Any snaps, zippers or eyelets used will be lead tested on site, prior to the products first use, if the manufacturer is unable to provide details/testing paperwork. If brands/suppliers are changed, a new lead test will be completed. 

Flammability testing is not required for plain surface textiles (smooth, woven and knit fabrics), as long as they are over 2.6 oz. per square yard.  Fabrics with pile (a fuzzy surface) do require flammability testing, if they are going to be used in children's clothing.  Flannel and cotton velour are good examples of fabrics with pile.   If required, I am also able to do flammability testing on site to confirm a textile is safe with the 45 degree burn test. 

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I also do not use any regulated phthalates in my items. For my 3D printed items, I use either PLA or PETG filament, which have all been labratory tested and deemed lead free and are safe for toys. However, I don't recommend them for ages under 8 due to their small parts, delicate nature for some pieces, dexterity required for certain items and intended play. 

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Small Parts Labelling

 

My items are geared mostly to collectors and customizers, however, I do understand that a lot of the items may be purchased for and used by children. Items, where required, will be marked with small parts warnings.  No product I make is intended for children under 3.  
 

How can I know if a small business meets CPSC safety requirements?

Most businesses will have a statement on their website, or listings, that says, "Meets CPSC Safety Requirements," though it is NOT required.  

There are also special labeling requirements which vary from item to item.  All children's products must have the following on their permanently attached label(s), with the exception of items that are very small or, in some cases, reversible.  If the item is too small, the information may be placed on a hang tag or the packaging.  Care labels are only required for wearing apparel, which I do not make: 

• Who the manufacturer is (usually this is a business logo with name)

• How to contact the manufacturer (usually a website or email address)

• Where the manufacturer creates the product (City, Province or State, Country)

• When the product was finished (often included in batch ID)

• Fiber content (only required for certain items and not required to be permanently attached)

• A unique mark or number (batch ID) so you are able to follow recall instructions should the occasion arise.

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