| View previous topic :: View next topic |
| Author |
Message |
mollyodesigns
Guest
|
 Posted: Thu Dec 04, 2008 3:23 pm Post subject: |
 |
|
| Lisa DOWNTOWN JOEY wrote: |
| according to those quotes, for one of my button down shirts, it would be over $500 per style. Umm...I have 8 different button down shirts, 5 pants, 4 tshirts w/16 different graphics, 2 hats, and 3 jackets. At a minimum, I'm looking at $11,000 per season. 2 seasons = $22,000 a year. Lovely. |
Is that based on each style or doing it by sku number? |
|
| Back to top |
|
 |
J C Sprowls
Joined: 25 Mar 2006
Posts: 2004
|
| Posted: Thu Dec 04, 2008 3:25 pm Post subject: |
|
|
times colorways!
Remember: the current direction appears to be the SKU. Not the Style.
To help refine Stu's comment on the blog, UPCs go down to the size. SKUs typically don't.
Think of it like a shelf & box system. The "department" is the shelving unit. The "style" is the shelf. The SKU is the box; and, the UPC is the item within the box.
So, if you had 3 colorways of the same style, the boxes (i.e. SKUs) would be next to each other on the same shelf. |
|
| Back to top |
|
|
annika
Guest
|
| Posted: Thu Dec 04, 2008 3:52 pm Post subject: |
|
|
I spoke with someone at Bureau Veritas who also stressed the "reasonable testing program" language. With clothing (and my product, baby carriers) the components do not change in the manufacturing process--they're not heated, melted, chemically tranformed in any way, they're just sewn together. If you test the components (and test once for components used in multiple styles/items), we can be assured they are NOT changing in composition because we sewed them. This is a "reasonable testing program." The issue is that BV (or the other labs I presume) will not put themselves on the hook for certifying your skus, since they didn't test the finished unit. But you can issue your GCC (General Conformity Certificate) still and use the testing of the components as the data backing up that certificate. I hope.
Last edited by annika on Fri Dec 05, 2008 11:14 pm; edited 1 time in total |
|
| Back to top |
|
|
mollyodesigns
Guest
|
| Posted: Thu Dec 04, 2008 4:30 pm Post subject: |
|
|
| annika wrote: |
| I spoke with someone at Bureau Veritas who also stressed the "reasonable testing program" language. With clothing (and my product, baby carriers) the components do not change in the manufacturing process--they're not heated, melted, chemically tranformed in any way, they're just sewn together. If you test the components (and test once for components used in multiple styles/items), we can be assured they are changing in composition because we sewed them. This is a "reasonable testing program." The issue is that BV (or the other labs I presume) will not put themselves on the hook for certifying your skus, since they didn't test the finished unit. But you can issue your GCC (General Conformity Certificate) still and use the testing of the components as the data backing up that certificate. I hope. |
The only thing that would make me nervous about doing that is that they are talking about all the lawsuits that are going to come out of this. People claiming that their child got sick, etc. from using your item. If you don't have a lab to back you, it could become a nightmare. But then again, I don't know enough about this to really have a solid opinion :) I truly hope the "reasonable testing program" is a viable alternative for those of us that have smaller companies. Fingers crossed! |
|
| Back to top |
|
|
Miracle
Site Admin
Joined: 13 Jan 2006
Posts: 946
Location: CA
|
| Posted: Thu Dec 04, 2008 4:47 pm Post subject: |
|
|
| Quote: |
| Think of it like a shelf & box system. The "department" is the shelving unit. The "style" is the shelf. The SKU is the box; and, the UPC is the item within the box. |
I just want to clarify this: in proper warehousing procedure each individual variation would have a separate sku (stock keeping unit). this is to ensure that each individual item is picked properly. The problem is, this is not regulated. It's not law, which is why there are so many ways people do it. The Uniform Code Council (or whatev they are called now) designates how UPCs should be assigned and used so there is a standard.
And the lack of legal guidelines defining skus is probably why it's a BAD IDEA for this to be based on SKUs in the first place. Technically, if you manufacture your own goods, you could assign SKUs to cut pieces, trims, rolls of fabric, garment labels etc.. A sku is only a unit management construct. When I have to hand over trims to my contractor, I assign skus to them. Makes them easier to identify in the bill of materials.
Which legistlators came up with this legislation? sheesh! |
|
| Back to top |
|
|
Miracle
Site Admin
Joined: 13 Jan 2006
Posts: 946
Location: CA
|
| Posted: Thu Dec 04, 2008 4:50 pm Post subject: |
|
|
| Quote: |
| The only thing that would make me nervous about doing that is that they are talking about all the lawsuits that are going to come out of this. People claiming that their child got sick, etc. from using your item. If you don't have a lab to back you, it could become a nightmare. |
Let me just point one thing out:
Having a reasonable testing program, or certification or being in compliance with the law does not alleviate you from your liability in a lawsuit. |
|
| Back to top |
|
|
Kathleen F.
Site Admin
Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
|
| Posted: Fri Dec 05, 2008 2:46 pm Post subject: |
|
|
| annika wrote: |
| I spoke with someone at Bureau Veritas who also stressed the "reasonable testing program" language. With clothing (and my product, baby carriers) the components do not change in the manufacturing process--they're not heated, melted, chemically tranformed in any way, they're just sewn together. If you test the components (and test once for components used in multiple styles/items), we can be assured they are changing in composition because we sewed them. This is a "reasonable testing program." The issue is that BV (or the other labs I presume) will not put themselves on the hook for certifying your skus, since they didn't test the finished unit. But you can issue your GCC (General Conformity Certificate) still and use the testing of the components as the data backing up that certificate. I hope. |
Okay guys, everywhere on the web I'm seeing this. It is NOT true! We CANNOT test at the component level! Falvey reiterated this at the meeting (she was the keynote speaker). We must do unit testing. Also, "reasonable" is presumed to be a third party lab that is certified to do it by the CSPC. See [url=//fashion-incubator.com/archive/cpsia-unit-vs-component-testing/]this entry[/url] for a review. |
|
| Back to top |
|
|
Jesica Milton
Guest
|
| Posted: Fri Dec 05, 2008 4:57 pm Post subject: |
|
|
Seems like there is yet even more confusion on what consititutes reasonable testing. This etsy seller claims to have gotten advice from a CPA representative that component testing is ok. Considering what you all have been relaying here (testing per SKU)I'm not so sure that was good advice, but here's the thread:
http://www.etsy.com/forums_thread.php?thread_id=5942404&page=1 |
|
| Back to top |
|
|
Kathleen F.
Site Admin
Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
|
| Posted: Fri Dec 05, 2008 6:33 pm Post subject: |
|
|
Yeah, I read it and posted about it. She's wrong, or she misunderstood or something. I heard it straight from Falvey's mouth. We asked her point blank. I sat there and listened to her explain the reasons why chapter and verse so I'm not going to believe an unknown etsy person who spoke to an unknown testing person who the aforementioned person may have misunderstood anyway. It's also on the CPSC website, what else do people want?
However, she seems to be sympathetic to the need to change it but says it is beyond her power to do anything. She says this issue needs to be addressed before congress at next week's meeting. |
|
| Back to top |
|
|
Jesica Milton
Guest
|
| Posted: Fri Dec 05, 2008 6:35 pm Post subject: |
|
|
| Yeah I figured she was mistaken, considering that it's not what the legislation says. |
|
| Back to top |
|
|
Esther
Moderator
Joined: 17 Mar 2006
Posts: 1919
Location: ID Spudville
|
| Posted: Fri Dec 05, 2008 9:27 pm Post subject: |
|
|
| I am not sure that selling locally versus crossing state lines makes a difference in this case. There are certainly many aspects of this law, if pushed will have to be decided by the US Supreme Court. I am also sure that the regional CPSC reps are at a loss as to what to tell people and spreading even more confusion. |
|
| Back to top |
|
|
Pamela
Guest
|
| Posted: Fri Dec 05, 2008 10:28 pm Post subject: |
|
|
Here is the link for info to the Congressional Hearing on December 10.
On this page is a link to find your congressman, do it and sent them a letter. I did even though I am not the best at wording my concerns.
I just said what I felt and asked him to look into it. Gave him some sites for reference including FI, Nationalbancruptcyday.com.
http://cpsia-central.ning.com/notes/Congressional_Hearing--URGENT
Pam
Last edited by Pamela on Sat Dec 06, 2008 12:19 am; edited 1 time in total |
|
| Back to top |
|
|
annika
Guest
|
| Posted: Fri Dec 05, 2008 11:36 pm Post subject: |
|
|
| Kathleen F. wrote: |
Okay guys, everywhere on the web I'm seeing this. It is NOT true! We CANNOT test at the component level! Falvey reiterated this at the meeting (she was the keynote speaker). We must do unit testing. Also, "reasonable" is presumed to be a third party lab that is certified to do it by the CSPC. See [url=//fashion-incubator.com/archive/cpsia-unit-vs-component-testing/]this entry[/url] for a review. |
I know what it says but again I can't believe that even Falvey doesn't recognize that is absurd. Unit testing only means that Intertek gets to take $70 from me 8 times to test the exact same buckle instead of taking it once. Considering the labs are already overbooked, it certainly doesn't serve anyone's interests to have them performing asinine redundant testing; it backs up the labs and prevents real testing from occurring in a timely manner. Which is counter to the goal of the law, which one presumes is increased safety.
Also, when I said "reasonable" I did mean using an accredited lab, but I think you'd be hard-pressed to show that component testing, in many cases, is not the most reasonable testing program possible. This is the problem with writing a law that is really about one specific product or product class and then saying "and it applies to the lot of you, too!" Maybe, gee, it would have been nice if part of the timetable was sitting down with industry leaders in different product classes and discussing what kinds of testing made the most sense given the type of product and the manufacturing process. The reasonable testing program language is in place for February and for August I do believe it then switches to "accredited third-party testing of product."
I'm just at a loss because if I do component testing, I will send off about 35 components used across 4 product lines for about 25 SKUs and do 35 lead tests (maybe throw in a few lead on surface tests too) and can manage this and know exactly what kinds of (probably 590 ppm lower than the federal guidelines) levels are going into all my products. If I do unit testing, I will send them completed units and the only thing they will be able to do to them is chop them up and test the components, except now I will have to pay exponentially higher cost--really such a high cost that I could not afford to do business.
I certainly hope the hearing results in an action to amend the law. If not, there will tons of people who are not compliant--not in a defiant way, but in a defeated, trying to hold onto their businesses and show they are doing what they can to show they do and always have made safe products (yes, that should have hyphens, too hard to type fast). That would be a lot of lawsuits. And someone is going to sue the federal government over this, mark my words.
Also, regarding interstate commerce, I hadn't thought of this, but if this is federal and you make and only sell locally, is that even within the jurisdiction of the CPSC?
If Falvey understands the absurdity of this, can she not make any recommendations? |
|
| Back to top |
|
|
April
Guest
|
| Posted: Fri Dec 05, 2008 11:48 pm Post subject: |
|
|
I produce children's clothing - newborn to 4T.
I don't know what I am going to do after Feb. 9th. I might have to give it all up and go back to working for the 'man'. I could possibly switch product categories and start doing women's, teens, or housewares. I make a lot of one-offs or few of a kind children's items, which is obviously not going to be an option in the future. |
|
| Back to top |
|
|
Kathleen F.
Site Admin
Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
|
| Posted: Sat Dec 06, 2008 2:41 pm Post subject: |
|
|
| annika wrote: |
| I know what it says but again I can't believe that even Falvey doesn't recognize that is absurd. ..If Falvey understands the absurdity of this, can she not make any recommendations? |
Falvey has suggested we lobby Congress to address this issue. Her hands are tied as the law is written. She makes a convenient target for ire but this is the reality. Do remember I'm on your side, but some people interpret "changes" to components very loosely. This is also my experience with customers. Just the other day, a tee shirt was recalled because the paint had lead in it. Sure, the tee shirt passed and the "minor" change was just the addition of a print but it wasn't safe. I also mentioned in one entry that we're often working off of prototype components of which the production values may vary. That said, I think better guidelines can be created. |
|
| Back to top |
|
|
|
FAQ 
Search 
Memberlist 
Usergroups
Register
Profile 
Log in to check your private messages 
Log in
