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Verifying a manufacturer's GCC statement

 
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Jessica Smith
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PostPosted: Tue Jan 20, 2009 1:07 pm    Post subject: Verifying a manufacturer's GCC statement Reply with quote

Hello
I am a small children's retailer. I just spoke with a small "custom" children's t-shirt maker who is ready to ship me my spring wares. I asked for her GCC to keep on file with her products. I have been instructed to keep a copy of all GCC for all products on hand by my trade organization. She told me that she would never have end-product testing done on her swarovski crystal t-shits. She told me that she has test results for the crystals and test results from American Apparel coming. I was under the impression that the test results have to be for the finished product. She yelled at me...for a while.
Could someone clarify for me:
1. Is componant testing okay, or is the testing neccessary for end product the requirement?
2. As she claimed...are "custom" products exempt from this regulation?
3. Is it fine to accept these products without a GCC before Feb.10th and still sell them after Feb. 10th through August?

Thank You.
Jessica
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Jessica Smith
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PostPosted: Tue Jan 20, 2009 1:21 pm    Post subject: and.... Reply with quote

I didn't mention that I would really like to carry this woman's wares. I just don't want to put my business at risk.
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Melanie
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PostPosted: Tue Jan 20, 2009 1:24 pm    Post subject: Verifying a manufacturers statement Reply with quote

I would suggest emailing her the link to the CPSC page, and have her read the law, and then the advisory opinions...she's obviously NOT informed...if she is the manufacturer, she must supply those certificates to you...and then after August, she has to have them 3rd party tested at a lab...also since you're dealing with those crystals, they most likely will be over the legal limit too, so you could be in trouble here if you sell them...check it out with Jennifer at the smart mama (she has posts under XRF testing), but I believe those crystals, don't pass muster with the new law...and your manufacturer has no clue she's about to be hit by a train!
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Valerie Burner
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PostPosted: Tue Jan 20, 2009 1:27 pm    Post subject: Reply with quote

Jessica, I would suggest you read as much as you can on here, and I think your questions will all be answered. But, in a nutshell, NO to all your questions above. AND Swarovski crystals are loaded with lead, so if they are on the finished product, it would not get a GCC anyway.
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Jessica Smith
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PostPosted: Tue Jan 20, 2009 1:31 pm    Post subject: thank you Reply with quote

Thanks all for your reply. What a great resource this is. Your answers have confirmed what I already knew, this woman just had me questioning myself. Good luck to her, and all of us:)
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Sarah Manello
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PostPosted: Wed Jan 21, 2009 11:08 pm    Post subject: swarovski crystal IS leaded crystal Reply with quote

this is kinda a damned if you do and damned if you don't.

Someone can't use a brand name and use a lesser or alternative product. So in other words if she is saying Swarovski crystal it has lead because that is what makes it so pretty and reflective. If it is a low lead crystal it isn't the name brand so she has to say "crystal." I know very little about crystal and don't know if there ar lead free or low lead crystals. I am fairly certain that Swarovski is intended for adults because of the lead content. There was a time in recent memory they were just called "leaded crystal" and people knew that meant pretty and super reflective. I *think* they are at least 21% lead to consider being leaded crystal.

It's the same way people confuse kleenex and tissues. kleenex is a brand tissues are the item.

This is also sadly an example when a handmade product could be dangerous when the maker had the best intentions. She might have no idea she is selling a dangerous item and I doubt her clients are eating their shirts. But one never knows what people really do with stuff after they buy it.
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Valerie Burner
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PostPosted: Thu Jan 22, 2009 5:41 am    Post subject: Reply with quote

Swarovski crystal is at least 30% lead. The higher the lead content, the "better" the crystal. Considering the fact that the CPSC's goal is to get lead content down to 100 ppm, and 100 ppm=0.01% lead, 30% lead content would not pass the test.

Things such as glasses and decanters are beautiful in crystal. But they have been warning for years now not to store anything in them, especially things like red wine, as it can leach the lead out into the liquid.

Swarovski does claim that the lead in its crystals cannot leach out, so is not harmful, but the CPSC is looking for lead in ppm, and that would certainly not pass the tests.

Other things that I have read say that the GI tract doesn't really absorb that much lead, and that inhalation is the most common route for ingestion into the body.

It doesn't really matter what the brand name is- it's the lead content of the item in ppm.
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Textilesavvy
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PostPosted: Thu Jan 22, 2009 9:23 am    Post subject: JESSICA's PRODUCT Reply with quote

Hi Jessica,
Assuming these are for childrenswear:
The importer is responsible for issuing a GCC. If your crystals have a surface coating on them, they need to be tested by a 3rd party accredited lab for lead in surface coating. A 3rd party test report has been required since Dec.21, 2008. You must have a GCC and a 3rd party test report for every style and every colorway within a style if there is a surface coating on these crystals.
If they do not have a surface coating on them, then you will just test for lead in substrates. Lead in substrates will also be tested on the shirt/tank fabric itself as well as the care label. That is 3 substrates right there that will need to be tested and compliance appear on a GCC. If these are for children, they will also need to be tested for flammability of wearing apparel 16 CFR 1610 as well as Child Safety 16 CFR 1500.48-53 (these are both included in the CPSIA). Please note, lead in substrates is not required to be tested by a 3rd party accredited lab until August 14, 2009.

If these are for adult wear:
You will only be required to obtain a GCC and be in compliance with flammability of wearing apparel 16 CFR 1610. Most of the time a manufacturer will have these results for you.
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Esther
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Joined: 17 Mar 2006
Posts: 1919
Location: ID Spudville

PostPosted: Thu Jan 22, 2009 1:08 pm    Post subject: Reply with quote

While GCC's are required by law, some Big Box retailers are requiring copies of actual lab results because GCC's can be based on absolutely nothing. If one is intent on not obeying the law, it would be very simple to just make it up.
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Sarah Manello
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PostPosted: Thu Jan 22, 2009 2:55 pm    Post subject: to rephrase Reply with quote

Sorry, my post wasn't clear. What I meant was that the maker of the shirts had a level of dishonesty across the board.

That if they were in fact real Swarovski and not just "some cystal" they are DEFINITELY leaded. And if it is not Swarovski she was illegally using their name and misrepresenting the item to get better sales with a recognizable name. But yeah, regardless of the brand lead content has to be the same. I don't know lead counts in other brands just that Swarovski certainly has it.
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Jennifer, Thesmartmama
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PostPosted: Thu Jan 22, 2009 6:10 pm    Post subject: Lead in crystals Reply with quote

And if she claims she has a test report for the cystals, it is NOT for total lead content, as required. I have a test report from Oeko-Tex for crystals as a Std. 100, Class II product, and I have spoken with Oeko-Tex about it specifically. Before 1/1/09, the Std. 100 testing was for leachable or extractable lead, not total lead. As of 1/1/09, the testing is for both total and extractable. So, in any event, crystals may pass the leachable test, but NOT total as required by the CPSIA.

Jennifer Taggart
www.thesmartmama.com
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Marian Thompson
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PostPosted: Fri Jan 23, 2009 9:47 am    Post subject: Adult Wear Question Reply with quote

"If these are for adult wear:
You will only be required to obtain a GCC and be in compliance with flammability of wearing apparel 16 CFR 1610"
-------------------
Does all adult wear per 16 CFR 1610 also now have to be in compliance with flammability requirements? For example if the adult wear is a t shirt and not sleepwear, does it still need to meet this requirement?
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Dawn Bucholtz
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PostPosted: Sun Jan 25, 2009 6:57 pm    Post subject: Reply with quote

I have gotten a few GCCs now and many of them are extremely flimsy in terms of content. They supposedly show lab test results on certain fabrics.
The exact name of the company can be "removed for downstream clients". What is actually tested is vaguely labeled, eg, "knit apparel fabric." There might be a line that says "no lead found" and an impossible to read signature at the bottom.
In other words, extremely easy to fake. In fact, the ones I have are so vague, I could claim they apply to many of my fabrics.
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