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CPSIA: Working with related industries and kindred
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Kathleen F.
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PostPosted: Sat Dec 13, 2008 11:48 am    Post subject: Reply with quote

First, I deleted some posts, most of them mine in attempt to streamline the topic. Again, this thread is to report actions involving related industries. By all means, continue to post news of related sewn products people in the appropriate threads.

Here's the latest from Rick -who's obviously getting a bit testy Smile. The testing quotes he mentioned are uploaded for your examination (pdf).
Quote:
No More Telescopes - Congress Wants You To Squint Instead

To: Judith.bailey@mail.house.gov, Christian.fjeld@mail.house.gov
Cc: nnord@cpsc.gov, jmartyak@cpsc.gov, tmoore@cpsc.gov, jmullan@cpsc.gov, Brian_hendricks@hutchison.senate.gov, david@commerce.senate.gov, Shannon.weinberg@mail.house.gov, Brian.mccullough@mail.house.gov, Cathy.hurwit@mail.house.gov, "Larry Lynn" <LLynn>, MToro@cpsc.gov, william.carty@mail.house.gov, patrick.magnuson@mail.house.gov

I am writing to follow up on the below email on the cost of testing under the CPSIA. The attached document is a quote we received to test ONE telescope product under the CPSIA. The cost of the testing is a mere $24,050 for this single item. The average annual sales of this item are approximately $32,000 over the past two years. Needless to say, we cannot afford to spend $24,050 to test this (or any) item. I presume that Congress intended this result and wants us to stop selling telescopes to keep everyone safe. I guess kids can see the planets by squinting from now on. Thanks, Congress!

This absurd result is increasingly common under the destructive and poorly-conceived CPSIA. It is not surprising to me that a law born out of anger and written in a spirit of retribution has created market chaos and many unintended consequences. In my prior correspondence, I have set out many dangerous and unacceptable effects that are wreaking havoc among law-abiding companies. Good corporate citizenship is no help when facing a law which markets itself as “pro-safety” but cripples companies with unbearable financial burdens and pointlessly complex compliance requirements that redirect safety investments into bureaucracy. The CPSIA is simply an invitation by the Federal Government for all children’s products companies to find something else to do.

My letters to you are of public record. We are posting them on the Internet for all to see and read. These letters have put you on notice of many problems the CPSIA is creating. When the damage takes place, there will be no way for legislators to disclaim responsibility. I don’t want to see the destruction happen, which is why I keep writing you. It is unnecessary and will have lasting effects if not arrested now. I call on you and on Congress to act promptly to convene hearings on the effects of the CPSIA on commerce and markets, and to take immediate steps to partner with industry and the CPSC to rebuild a truly effective CPSIA to address real (not imaginary) children’s products safety issues. A stripped down, but focused, CPSIA could add a great deal of safety value without weakening companies, markets and the economy. A vindictive CPSIA salted with bitter distrust and enmity toward industry will simply gut markets and weaken the regulators’ ability to patrol markets for real safety issues. The choice is obvious – I urge Congress to choose the right path for our country.

Sincerely,

Richard Woldenberg
Chairman
Learning Resources, Inc.
----------------------------------------
From: Rick Woldenberg
Sent: Wednesday, November 26, 2008 12:34 PM
To: Mary Toro (MToro@cpsc.gov)
Cc: Nancy Nord (nnord@cpsc.gov); Joe Martyak (jmartyak@cpsc.gov); 'tmoore@cpsc.gov'; 'jmullan@cpsc.gov'; 'Judith.bailey@mail.house.gov'; 'Cathy.hurwit@mail.house.gov'; 'Christian.fjeld@mail.house.gov'; 'Brian.mccullough@mail.house.gov'; 'Shannon.weinberg@mail.house.gov'; 'Brian_hendricks@hutchison.senate.gov'; 'david@commerce.senate.gov'
Subject: Cost of Testing

Mary,

I want to continue our dialogue over the issues presented by the CPSIA. I realize you are swamped with inquiries from many sectors, so I thought I would send this comment in via email.

I have previously raised the serious issue of the high cost of testing under the CPSIA. To be clear, the issue is not about the testing per se, rather it is the cost of the testing to prove compliance with the CPSIA. It is our legal obligation to produce products that comply with the law, of course. Financing proof of that compliance is the problem that confronts industry right now.

The attached lab test is a great example of the dilemma caused by the CPSIA testing requirements. The item in question is a new item called Let’s Tackle Kindergarten. This item is similar to other items in our product line and is quite uncontroversial from a safety standpoint. Because of our experience testing virtually identical items, we know this item is in compliance with the CPSIA on phthalates, lead and its other requirements. Nevertheless, to prove compliance, we will apparently have spend $6,144.06 on myriad tests. The product will be no more or less safe after this expenditure. No child will be safer or better protected. Our company will simply be much poorer.

High testing costs will have a significant effect on our business and businesses like ours. First, the cost of testing has increased about 5x – 20x under the new law. We do not believe these costs can be recovered because under current economic conditions, raising prices is not an option. Thus, the breathtaking increase in cost becomes part of our overhead.

The testing costs cannot be absorbed by small and medium-sized businesses. At typical net profit levels prevailing in the children’s products industry, the $6,144 cost of testing probably exceeds the anticipated total net profit derived from three or more years’ sales of the item. This does NOT take into account the cost of development, the cash expense of buying the inventory or the cost of owning inventory (usually estimated at 2.5% per month). Given that children’s products have finite commercial lives (three years is a good life for a consumer product), the CPSIA test costs might exceed the present value of creating a new item for many, if not most, businesses. So, will this product ever come to market? Not under the CPSIA. The only products left for sale will be mass market items where the scale of their production runs can support this wasteful expense. I believe this “mass market world” is not in the national interest as specialty companies like Learning Resources are an important means by which consumers obtain the products and services they need in our economy.

Notably, the gross cash expense required to finance these tests right now is literally unbearable. The law requires that all of this testing must be completed on all products in our line all at once. Several years of “catch-up” testing must be financed in just a matter of a couple months, bunching up the vast expense into one or two financial statements. Together with other excessive costs suddenly imposed by the CPSIA (for instance, lot traceability infrastructure), the economics of producing children’s items are being distorted into an unrecognizable form. If children’s products companies cannot produce a fair profit, they won’t be able to attract financing or risk capital, and the jobs (and products) will disappear. This problem needs a solution fast, and if we can’t come up with one, no one in Congress or the CPSC should be surprised to see bankruptcies rise inexorably as a result. The price will be paid.

I would appreciate the opportunity to dialogue with you on these rules and other negative incentives under the CPSIA. I am confident that through a partnership with industry, the CPSC can develop a common sense approach to safety rules and enforcement that will reward those companies committed to compliance while discouraging the bad actors who give the children’s products industry a bad name. The time to act is now. My associates in the business community are under intense pressure to pay these exorbitant testing bills – and once the money is shipped to the Chinese testing companies, there will be no getting it back.

Thank you for considering my views on this important topic.

Sincerely,
Richard Woldenberg
Chairman
Learning Resources, Inc.
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Kathleen F.
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PostPosted: Sat Dec 13, 2008 2:04 pm    Post subject: Reply with quote

Oh my, new "friends". It seems the Boy Scouts of America are in trouble too. I imagine that would apply to Girl Scouts etc
Quote:
There has been some discussion over the effects of the legislation on the patch collecting hobby. The Boy Scouts of America (BSA) has already responded with new requirements to be imposed upon its licensed vendors in an attempt to ensure those vendors and the BSA are in compliance with this law.

A friend of mine, who requested to remain anonymous was recently discussing this issue with a patch manufacturer and sent me the following message. I am quoting it with his permission

Click through for the rest. A previous related article from the same site (also boy scout related) is here.
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Valerie Burner
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PostPosted: Sat Dec 13, 2008 3:43 pm    Post subject: Reply with quote

Oh my, is right, Kathleen. I have been quiet on this CPSC stuff for a while, just reading everything and trying to figure out how best to handle the article for Apparel News and others, and after reading Rick's letter and the Boy Scout article, I am ready to just scream and pound my fists on the table.

It is beyond me how the CPSC can expect companies to spend that much money on the testing of a product that is, at this time, totally legal and safe for kids.

But the thing that bothered me most was the "annonymity" of the "vendor" for the Boy Scout patches. It seems that people are literally afraid. Paranoid. Of what? The CPSC? If so, we're all in trouble. Isn't this the USA? Land Of The Free, Home Of The Brave?

Then at the end of the Boy Scout article, this quote appeared.

"When in the pursuit of happiness Obstacles cross our way, When all seems lost And there is a darkening of the day. Remember God in His heaven And it does not cost to call. We'll find despite our troubles We've been blessed after all. "
Janet Louise Holman

[/i]
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Eric H
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PostPosted: Mon Dec 22, 2008 8:04 pm    Post subject: Reply with quote

Not sure what to make of this from kidstodayonline:
Quote:

The California Attorney General’s office distributed this letter, Dec. 3 to the CPSC regarding its phthalates bill. Here’s the first paragraph of the letter:

“In light of the recent public debate concerning the applicability of the federal phthalate restrictions in the Consumer Product Safety Improvement Act of 2008 (“CPSIA”), we are writing to explain our position on the applicability of California’s phthalate limits on toys and child care articles. In short, California’s phthalate restrictions become effective January 1, 2009, and prohibit the manufacture, sale, or distribution of toys and child care articles with excessive levels of certain phthalates, regardless of when or where those items were manufactured.”

I'll be cross-posting in online, also, but at the very least it may have an effect on Californians.
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PostPosted: Mon Dec 29, 2008 5:54 pm    Post subject: Reply with quote

Cross posted from Rob Wilson, cpsia central

Rob Wilson wrote:
Hi Everyone:

First, I hope everyone is enjoying the Holidays as well as possible.

First, one timely matter:

The LA Times is writing an article to print on New Year's Day. They need more apparel companies to interview. If you are interested, please let me know ASAP.

Now, here are some updates:

-The National Association of Manufacturers has sent a petition to the CPSC asking for exemptions of certain materials, products with non-soluble lead, etc. You can access it from the Petition tab. Please take the time to review it and send the CPSC & Congress a note indicating your support.

-The CPSC has requested comments regarding 3rd Party Testing, including component versus unit testing. I encourage you to send your personal comments to the CPSC. I have posted a link in the notes section.

-The CPSC has released proposed rulemaking in relation to exemptions for natural materials. There are links in the “notes” section. Please send your response in support of such measures, while encouraging them to go further (to allow for colors, etc).

- Finally, I am trying to start sending regular emails to the CPSC, key staff members of the sub-committee that wrote the CPSIA, as well as key Senators and Representatives of Congress. It is great to send one email, but it is better to send an email once per week, or even more frequently, with updates on your perspectives, what is happening in your business due to CPSIA etc. They need to understand what is happening out here, on a regular basis, from YOUR perspective. Remind them that there are many ways to ensure continued safety of our products, without sacrificing most of the industry.

I sent such a letter today, and you can see the emails on the header (I posted it as a blog, and in the forum).

Thanks for all of your efforts. Please remember that you can use the CPSIA-Central as your soap box and an additional forum for speaking out about the CPSIA.

Sincerely,

Rob Wilson

Visit cpsia-central at: http://cpsia-central.ning.com
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lisa versaci
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PostPosted: Sat Jan 03, 2009 12:54 am    Post subject: Reply with quote

If we're talking about "joining forces" here why not ask our local health depts. to step up and offer FREE lead testing days. It's not unheard of....

http://www.wishtv.com/dpp/news/consumer/local_wish_indy_free_lead_testing_for_toys_20081208652
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PostPosted: Sat Jan 03, 2009 1:15 am    Post subject: The Affect on the Fair Industry Reply with quote

I have written the WFA, (Western Fairs Association), as you can imagine the affect on fairs could be tremendous. The information has been passed along to their legal counsel and lobbyist to figure out the ramifications to the industry. Its important, because come Feb 10th, the National Date Festival in Indio, CA opens for its ten day run. Novelty sellers, carnival plush, toy vendors, almost all product vendors and perhaps even food vendors could be affected by this legislation.

regards

abigkahuna
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Kathleen F.
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PostPosted: Fri Jan 16, 2009 1:12 pm    Post subject: Reply with quote

Two meetings with the CPSC have been scheduled for next week. One is for apparel, the other for books.

Quote:
Thursday, January 22, 2009 10:00 AM: Apparel
*Kristina Hatlelid, Directorate for Health Sciences, and other CPSC staff meeting with Stephen Lamar of the American Apparel & Footwear Association and Stephanie Lester of the Retail Industry Leaders Association to discuss lead content of apparel; 10:00 a.m., Bethesda Towers, room 410 a/b/c. The meeting was requested by Stephen Lamar. For additional information contact Kristina Hatlelid, (301) 504-7254. Posted on Master Calendar 1/12/09. (S)

Thursday, January 22, 2009, 1:00 PM: Books
*Kristina Hatlelid, Directorate for Health Sciences, and other CPSC staff meeting with Allan Robert Adler, Association of American Publishers, to discuss lead content of books; 1:00 p.m., Bethesda Towers, room 410 a/b/c. The meeting was requested by Allan Adler. For additional information contact Kristina Hatlelid, (301) 504-7254. Posted on Master Calendar 1/13/09. (S)

To learn more about problems with the new product safety bill and to send a message to your U.S. Representative or Senator, please visit: http://tinyurl.com/5hloos
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PostPosted: Fri Jan 16, 2009 2:11 pm    Post subject: Reply with quote

They really should have done this kind of thing months ago. If they are planning to make exemptions for apparel, allow XRF testing and component testing, etc. they had damn well better issue some kind of notice about it before Feb. 10. Even if it's not an official rule (I know they have to go through the process and it takes months) issuing a notice would declare their intent. It is the uncertainty more than anything else that is killing all these businesses. The more they drag out the uncertainty, the more businesses will die.
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PostPosted: Thu Jan 29, 2009 6:11 am    Post subject: Final Request for Emergency Stay of Effective Dates NAM Pet Reply with quote

NAM has created another petition, sent to the CPSC late yesterday. We, among many others were signatories. Below is the content of the message sent to the CPSC.

National Assoc of Manufacturers wrote:


NAM CPSC COALITION
January 28, 2009
VIA ELECTRONIC MAIL

Office of the Secretary
U.S. Consumer Product Safety Commission
4330 East-West Highway, Room 502
Bethesda, MD 20814-4408

Re: Request for Emergency Stay of Effective Date (CPSIA §101(a)(2))

Dear Mr. Stevenson:

On behalf of the Consumer Product Safety Commission Coalition of the National Association of Manufacturers (NAM CPSC Coalition), and the undersigned parties to this letter (hereinafter referred to collectively as (“the Requesters”), we respectfully request the Commission to issue an immediately effective emergency rule staying the effective date of limits on lead content in accessible parts and components in children’s products established under Section 101(a)(2) of the Consumer Product Safety Improvement Act of 2008 (“CPSIA”) (Pub. L. 110-314). The length of the requested stay is 185 days, or until 90 days after final comprehensive rules and interpretative regulations implementing Section 101 are issued, if later. We do not think that when it adopted the deadlines in the CPSIA Congress realized or intended to effectuate a massive economic dislocation at a time when so many businesses are teetering on the edge of financial ruin and we are suffering the largest job losses in decades.

The current effective date of February 10, 2009 for the new lead content requirements is less than two weeks away. The law requires manufacturers and importers of children’s products to issue certificates that newly manufactured or imported products comply with the lead content requirements. In addition, under an opinion issued by the CPSC General Counsel, previously manufactured products in existing inventory which do not comply with the lead content limit for accessible parts may no longer be distributed or sold.

It has become clear that compliance with these new lead content requirements will be a practical impossibility for thousands of manufacturers, distributors, retailers, and resellers on February 10, 2009. While the Commission has issued several notices of proposed rulemaking regarding the interpretation of which parts and components are considered to be accessible and thus subject to the lead content limits, proposing exclusions for a limited number of materials, and proposing procedures and criteria for making additional exclusion determinations, the comment period on these proposed regulations will extend beyond February 10, 2009. These rulemakings clearly cannot be completed until well after the current effective date. Moreover, realistically it will be many months before the Commission is likely to act on petitions for permanent exclusions. In practice, many types of materials or products that will not expose children to harmful amounts of lead and are thus perfectly safe, based on reasonably foreseeable use and abuse conditions, will as a result be banned due to the inability to process petitions for permanent exclusions before February 10, 2009. We are aware that some industry sectors are preparing petitions for temporary exclusions and we urge you to grant these petitions before February 10, 2009. Experience under appropriate temporary exclusions can provide additional, useful information for the Commission when it begins to review petitions for permanent exclusions after that process is finally established.

In addition, the Commission has yet to even propose specific designated test procedures for lead content for any materials other than metal in children’s jewelry and lead in paint, or to clarify the critically important role of component testing within a regime of third party testing of children’s products by accredited laboratories. Manufacturers and retailers of thousands of children’s products containing parts made of various types of plastic, rubber, wood, composites, paper, fabric and other materials have no designated test method under which to determine the accessibility or lead content, if any, of these products or components thereof. In addition the definitions of component parts subject to regulation have yet to be finally determined.

Given the impossibility for many manufacturers and retailers to determine with any degree of confidence that all accessible parts and components of a particular children’s product do not contain lead above 600 ppm, the clear prospect is for massive disruption in the consumer product distribution and retail system beginning on February 10, 2009. Large amounts of safe product inventory whose compliance with the lead content requirements cannot be confirmed will be pulled from retail inventory or withheld from distribution. In many cases retailers are requiring the manufacturer to take the product back and offer credit for the unsold goods. Aside from the immediate financial hardship of handling product returns – which may amount to hundreds of thousands of dollars in particular cases – once inventories are unsalable, lines of credit to retailers or manufacturers secured by financial institutions may be rescinded, leading to the potential for widespread bankruptcies.

The chaotic application of yet-to-be established legal requirements to current inventories at retail potentially threatens to render obsolete billions of dollars of legally produced products already introduced into interstate commerce. In addition, the threatened wholesale destruction on February 11, 2009 of inventory which cannot be verified as complying with newly established requirements could inflict additional damage to the U.S. economy and threatens the ability of small American manufacturers and retailers to remain in business. The environmental impact of widespread destruction of unverifiable merchandise should also be considered. Further, companies have reported that the testing for CPSIA lead levels is different from the testing required by the Environmental Protection Agency (EPA). Thus, in addition to destroying merchandise that may in fact be CPSIA compliant but is unverifiable, companies are also incurring costs to determine how to properly destroy that merchandise.

Considering the breadth of potentially affected types of children’s products - shoes, apparel, bedding, jewelry and accessories, books, educational materials, electronics, luggage, toys, housewares, sports equipment, bicycles, recreational vehicles and home furnishings - clearly developed final regulations are first necessary to enable compliance determinations and effective enforcement. Otherwise tens of thousands of businesses and hundreds of thousands of employees could be adversely impacted. This position is consistent with recent correspondence from Members of Congress to the CPSC indicating that they did not intend such consequences from a chaotic implementation of the CPSIA. This developing situation in which products which may ultimately be determined to be in full compliance with the lead content requirements are nonetheless pulled from shelves and in some instances even destroyed in the middle of the worst economic environment for businesses and consumers in decades clearly does not serve consumer safety, the welfare of the public at large, or market stability.

Under Section 3 of the CPSIA, the Commission has authority to “issue regulations, as necessary, to implement this Act and the amendments made by this Act.” The Commission should exercise its authority to grant the requested delay. Under the doctrine enunciated in Chevron, U.S.A., Inc. v. Natural Res. Def. Council, 467 U.S. 837, 842-45 (1984), a regulatory agency is permitted to adopt a reasonable interpretation of a statute that Congress entrusts that agency to administer. In choosing among reasonable interpretations, an agency may consider their policy implications. Chevron, 467 U.S. at 843. Here, substantial policy implications point in favor of staying the effective date of Section 101(a)(2) until the final substantive rules and interpretative regulations can be established and regulated entities can, as a practical matter, determine whether particular new and existing products are in compliance with the lead content requirements.

As we noted, Section 3 of the CPSIA reaffirms that “[t]he Commission may issue regulations, as necessary, to implement this Act and the amendments made by this Act.” Moreover, the CPSIA adds, in Section 101, that a product containing more lead than the new limits “shall be treated as a banned hazardous substance under the Federal Hazardous Substances Act,” § 101(a)(1), and that a ban or rule pursuant to Section 101(a) “shall be considered a regulation of the Commission promulgated under or for the enforcement of section 2(q) of the Federal Hazardous Substances Act,” § 101(g). The Federal Hazardous Substances Act, in turn, requires the Commission in classifying an article or substance as a banned hazardous substance to craft a regulation that “imposes the least burdensome requirement which prevents or adequately reduces the risk of injury for which the regulation is being promulgated.” 15 U.S.C. § 1262(i)(2). Congress also left it to the CPSC to develop, as part of the overall regulatory scheme, regulations reasonably defining the scope of products and components subject to the regulation itself; the exclusions to be afforded, as mandated by Congress, to inaccessible components, excluded material and electronic components (CPSIA Section 101(b)); and the applicable test methodology to be employed. None of these requirements have yet been finalized for lead “content.”

The Administrative Procedure Act, 5 U.S.C. §553(b), authorizes the Commission to exclude rules from otherwise applicable notice and comment procedures where the agency for good cause finds such procedures are impractical or contrary to the public interest. Although well intentioned, piecemeal interpretative rulemakings that have a substantive impact on the marketplace require adherence to such due process procedures . Given the short time until the February 10, 2009, effective date and the absence of comprehensive final regulatory guidance on compliance, however, notice and comment procedures in this particular case are both impractical and contrary to the public interest and the Commission should issue an immediate final rule extending the deadline.

The Requesters fully support government efforts under the CPSIA to safeguard consumers and reduce their exposure to lead or other materials that could affect their health and safety based on sound scientific principles. However, retaining the current February 10, 2009 effective date for the lead content limit in accessible components will create massive marketplace confusion and business disruption without any commensurate benefit to consumer safety.

The business community appreciates the enormous effort the Commission staff has made since last August to complete the many rulemakings and other tasks that Congress required under the CPSIA. However, you and we are faced with an impossible situation. Time is needed for the Commission to complete the many rulemakings necessary to provide clarity on the Act’s requirements. Requesters hereby respectfully request that the Commission, on an emergency basis, use the discretion afforded it to issue an immediately effective rule delaying for 185 days, or until 90 days after final comprehensive rules and interpretative regulations implementing Section 101 are issued, if later, the effective date of lead content limits for accessible parts and components in children’s products.

Respectfully submitted,

American Apparel & Footwear Association (AAFA)
American Fiber Manufacturers Association
American Home Furnishings Alliance
American Specialty Toy Retailing Association
Amusement & Music Operators Association
Association for Safe Glass and Ceramicware
Association of American Publishers
Association of Home Appliance Manufacturers
Bicycle Product Suppliers Association
Book Manufacturing Institute, Inc.
California Fashion Association
California Retailers Association
Coalition for Safe and Affordable Childrenswear, Inc.
Coalition for Safe and Responsible ATV Use
Consumer Electronics Association (CEA)
Consumer Electronics Retailers Coalition (CERC)
Craft Yarn Council of America (CYCA)
Fashion Incubator Association
Fashion Jewelry Trade Association
Footwear Distributors and Retailers of America
Georgia Retail Association
Gift and Home Trade Association
Greeting Card Association
Handmade Toy Alliance
Illinois Retail Merchants Association
INDA, Association of the Nonwoven Fabrics Industry
Information Technology Industry Council (ITI)
International Association for the Leisure & Entertainment Industry (IALEI)
International Association of Amusement Parks & Attractions
International Sleep Products Association
IPC – Association Connecting Electronics Industries
Louisiana Retailers Association
Maine Merchants Association
Minnesota Retailers Association
Missouri Retailers Association
Motorcycle Industry Council
National Association of Manufacturers
National Bulk Vendors Association
National Council of Textile Organizations (NCTO)
National Retail Federation
National Textile Association
New Jersey Retail Merchants Association
Ohio Council of Retail Merchants
Outdoor Industry Association
Pennsylvania Retailers’ Association
Printing Industries of America
Promotional Products Association International
Real Diaper Industry Association
Retail Association of Nevada
Retail Industry Leaders Association
Retail Merchants of Hawaii
Retailers Association of Massachusetts
Retail Merchants Association of New Hampshire
Secondary Materials and Recycled Textiles (SMART)
Specialty Graphic Imaging Association
Specialty Vehicle Institute of America
Sporting Goods Manufacturers Association
The Hosiery Association
The International Snowmobile Manufacturers Association
The Juvenile Products Manufacturers Association (JPMA)
The National Cotton Council
Toy Industry Association
Travel Goods Association (TGA)
United States Association of Importers of Textiles and Apparel
U.S. Chamber of Commerce
Virginia Retail Merchants Association
Washington Retail Association


Last edited by Kathleen F. on Thu Feb 05, 2009 7:01 pm; edited 1 time in total
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Kathleen F.
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PostPosted: Thu Jan 29, 2009 9:02 pm    Post subject: Reply with quote

Moved entry

Trace wrote:
The CPSC Takes Questions from eBay Community
http://ebayinkblog.com/2009/01/28/the-cpsc-takes-questions-from-ebay-community/
(I don't know if you need to be a member of eBay to read/comment on the website, but the main issues are copied below)
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