Q.3 RFC Component v. Unit and 3rd party testing

[Eric H]

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at Introduction and Table of contents: RFC Component vs unit and 3rd party testing

This section deals with the third question which is:

[Eric H]

It would be best to allow third-party testing of component parts if there was some assurance that downstream processes did not substitute or fundamentally alter the materials during assembly, and if there was some assurance that no non-tested components could enter the final product. In apparel, natural fiber (wools, cotton, silk) are going to be naturally phthalate and lead free. Skins (leather) may depend on the tanning processes [I don't know enough about it]. However, those are not the sole components used in apparel.

Natural fibers must be dyed and perhaps have other chemical treatments applied. Fusibles, hardware, and other components may be introduced to the material. The common examples of this are the rubberized feet on sleepers and waterproof backing on bibs. If all are tested, there should be no problem.

Again, there is differentiation along the lines of established manufacturers with controlled processes and new entrants with poorly controlled processes. Startup manufacturers are going to separate out into those who use cotton cloth, polyester thread, and fusibles and those who use t-shirt blanks and all manner of glues, hardware, and inks. It will be more sophisticated manufacturers who get into rubberized footies, etc. The sophisticated manufacturers and the startups using cotton cloth could probably be trusted to use component testing. It's the graphic t-shirt and others using art supplies and experimental treatments that would be most worrisome.

This also applies to 2.The conditions and or circumstances, if any, that should be considered in allowing third-party testing of component parts.

[Vesta]

Same as Q2.

GOTS (Global Organic Textile Standards) processing is becoming more and more common these days. Even suppliers in China are on board. This standard allows something like 2 ppm lead. There are so many standards out there now that would assure compliance with the CPSIA lead content requirement, leaving manufacturers to focus on components that don't have such a clear provenance.

[Eric H]

I understand the Oeko-Tex bans lead, but I can't find anything about phthalates. Does anyone have any strong feelings and real experience with relevant international standards? How do they map?