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phthalates and existing inventory

 
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pmm
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PostPosted: Sat Dec 20, 2008 3:23 pm    Post subject: phthalates and existing inventory Reply with quote

Hi I just wanted to clarify for you all that there is a General Counsel Opinion Letter that was issued on November 17, 2008 which clarifies that with regard to phthalate prohibition (not lead) that existing inventory does not need to be pulled on February 10. The phthalate ban is considered a consumer product safety standard and under 15 U.S.C. 2058(g)(1) consumer product safety standards "shall be applicable only to consumer products manufactured after the effective date." Lead is now considered a hazardous substance under the Hazardous Substance Ace, so it does not fall under the same analaysis.

It seems that, with regard to phthalates, our general conformity certifications would only need to apply to product manufactured after February 10 and that retailers would not need to worry about existing inventory as it relates to phthalates.

Here is a link to the General Counsel Letter

http://cpsc.gov/library/foia/advisory/320.pdf
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Kathleen F.
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Location: NM Albuquerque

PostPosted: Sat Dec 20, 2008 4:10 pm    Post subject: Reply with quote

This has been duly noted many many times. But thanks for the reminder. Fwiw, I think everyone here is modifying their product offerings to stand clear of anything that could potentially be phthalate related. Call it a casualty, few of us can afford the testing to justify footed kids pajamas. Good luck to consumers finding those!
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ShariB
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PostPosted: Sun Dec 21, 2008 6:58 pm    Post subject: Reply with quote

I have a question about this I am wondering if anyone knows... Even if a child's product need not be tested for pthalates that exists in inventory, wouldn't it need to be tested for lead anyhow, so does not comply? I have a boutique full of items for girls age 0-4 and my understanding was that post Feb 10 everything will at the very least need lead testing so am I correct to assume that if I don't go out and test all my existing inventory (many OOAK) then it has to be pulled off the shelves Feb 10? Or are there exceptions I am missing that allow the inventory to stay until the August deadline?
I thought I 'got it' and then I read more & more and get thoroughly confused! So sorry if this has been answered before.

Shari
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Vickie
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PostPosted: Wed Jan 28, 2009 2:37 pm    Post subject: Reply with quote

Has anyone tested Velcro yet? Wondering if there have ever been any lead findings or evidence of phthalates. I realize component testing is not allowed, but if this is part of your finished product (like my bibs) then this info would be helpful.
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Anne
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PostPosted: Wed Jan 28, 2009 9:09 pm    Post subject: Reply with quote

Quote:
few of us can afford the testing to justify footed kids pajamas. Good luck to consumers finding those!


Doesn't all sleepwear need to be tested, footed or not? I emailed the CPSC that question, but no reply. I make bibs, too, but just cotton. I assume those will have to be tested as well.

I haven't tested velcro yet, but I see plenty of bibs (like Bumkins) that use velcro and advertise themselves as phthalate-free. So at least one type of hook-and-loop tape passes.
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Vickie
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PostPosted: Thu Jan 29, 2009 9:07 am    Post subject: Reply with quote

Thanks Anne - good to know.
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Charlotte Reppy
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PostPosted: Thu Jan 29, 2009 11:20 am    Post subject: Compliant suppliers Reply with quote

Here is a link to a central resource of suppliers who have supplied certification certificates for components (mostly craft, not commercial):http://cpsia-compliance.blogspot.com This list continues to grow. While we know that component testing has not yet been approved, for those people who cannot test their items it may be the beginning of what the good Ms. Vallesse refers to as "a comfort level."

I have posted the question about velcro testing, because I have some lovely handcrafted bibs in my webstore/retail store (www.grammies-attic.com) that I would be heatbroken to discontinue selling.
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Vickie
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PostPosted: Thu Jan 29, 2009 1:38 pm    Post subject: Reply with quote

Thanks Charlotte - that's a great resource. The type of Velcro I use is the "softer, more pliable" product that is commonly used with children's items. Hmmm. Phthalates are a plastic softener, right?...scary.
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