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Is a GCC required if I'm selling online direct to consumer?

 
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Parul
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PostPosted: Tue Jan 06, 2009 3:36 pm    Post subject: Is a GCC required if I'm selling online direct to consumer? Reply with quote

I'm a bit confused on the CPSIA requirements for GCCs. I plan on manufacturing children's clothing (haven't launched yet, trying to understand the implications of new regulations so I start on the right foot) and will be selling my items online directly to the consumer (via my own website, etsy, ebay, etc.) So I am basically acting as both the manufacturer and the retailer, right?

Let's assume that for everything I produce between Feb 10, 2009 and Aug 16, 2009 I'll get all my styles XRF scanned for lead and that I won't use any plastics/PVC/etc. so I won't have to worry about phthalates (is that a safe assumption?). So my head doesn't explode, I'm just going to focus on what I manufacture before Aug 16, 2009 and deal with 3rd party testing once I'm sure that it is necessary.

Okay, so back to GCCs:
My understanding is that after Feb 10, 2009, manufacturers of children's products need to supply a GCC for each style to retailers stating that the style meets reasonable testing requirements for lead and phthalates. But since I'll be selling directly to the consumer, how do I handle this? I am thinking that the best thing to do is have a GCC on file for each style in case it is requested by the CPSC or a consumer, but there is no need to include copy with each garment I sell to consumers.

Of course, if I sell wholesale to retailers in the future, I would include a GCC for each style as the CPSIA dictates.

Does this sound correct to you guys? I know that we are all confused; I guess I'm just looking for some reassurance. I have been traveling and away from F-I since mid November, so I am just becoming aware of these new regulations and a bit overwhelmed. I apologize if this has been discussed elsewhere in the blog or forum -- I've been reading all day and haven't been able to find an answer.
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Tue Jan 06, 2009 5:05 pm    Post subject: Reply with quote

I think it's even simpler. You're a retailer who manufactures a product.

Since you are a retailer, your "manufacturing division" needs to provide a GCC to the "retail division".

As for the end consumer, there is nothing in the current legislation that indicates the consumer needs to receive anything other than a safe product.

However, I would recommend taking advantage of the electronic document provision in the Act and publish on your manufacturing division's website a scanned image of the GCC by Style#, Lot# and Date of Manufacture.

If you receive calls from errant Consumers, you can save face and avoid a lengthy argument (which you'd never win, anyway) by directing them to the manufacturer's website.

Though, do yourself a favor. Since there are no free lunches, require an email address and have a list server email them the document. It'd be interesting to see if your competition is fishing to make sure you're in compliance. Because, that dirty game is just waiting to ramp up.
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Vesta
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PostPosted: Tue Jan 06, 2009 7:55 pm    Post subject: Reply with quote

Yup, I've seen that dirty game played with the EU regulations for baby carriers. Manufacturers "checking up" on other manufacturers, and definitely catching people in lies . . .
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