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Is Everyone Ready For Jan. 1, 2012? CPSIA

 
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Renee Tice
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PostPosted: Tue Dec 06, 2011 9:07 am    Post subject: Is Everyone Ready For Jan. 1, 2012? CPSIA Reply with quote

I noticed this come through my email inbox last month and am circling around to deal with it now. I'm really surprised no one on this forum has mentioned it as yet:

Dear CPSC Small Business Community:

As you may know, on January 1, 2012, manufacturers and importers of children’s products will be required—for the first time under federal law—to third party test and certify their children’s products for compliance with the limit on total lead content in children’s products. Manufacturers and importers will also be required to third party test and certify that toys and certain child care articles are compliant with the federal toy safety standard and the ban on certain phthalates. We are reaching out, in the spirit of partnership, to provide you with new and updated education and guidance materials (described below) to ease the transition for affected businesses as the stays of enforcement expire for these regulations. We want to work with you to ensure that you are familiar with these new requirements and to address your concerns.

Toy Safety Standard & the Ban on Phthalates

Recently, the U.S. Consumer Product Safety Commission (the “Commission”) announced the development of a strategic outreach and education plan to help the business community and other stakeholders learn about the third party testing and certification requirements that will go into effect on January 1, 2012, for children’s toys and toy chests manufactured after December 31, 2011. For more information on the toy safety standard, please see our website at: www.cpsc.gov/toysafety. Also, while you are visiting our website, please review our strategic outreach and education plan in the upper right hand corner of the page, and provide us with additional ideas and feedback about our plan.

Third party testing and certification requirements will also go into effect for the ban on certain phthalates for children’s toys and certain child care articles manufactured after December 31, 2011. For more information about the ban on phthalates in toys and certain child care articles, please see our website at: www.cpsc.gov/phthalates.

Total Lead Limits in Children’s Products

January 1, 2012 also represents the date on which the Commission will begin to enforce the third party testing and certification requirements for the total lead limit of 100 parts per million in accessible parts of children’s products. Unlike the toy and phthalate requirements, this requirement is for children’s products manufactured after August 14, 2011. For more information about the total lead limits in children’s products, please see our website at: www.cpsc.gov/lead.

Certification and Third Party Testing

For all children’s products safety rules, certification and third party testing are generally required. Certification means that manufacturers and importers of children’s products must issue a written Children’s Product Certificate (CPC) for each product, which identifies the product, the rule or standard with which it must comply, the third party laboratory where it was tested, and other requirements. Certification must be based upon the results of third party testing, which means testing performed by a third party, accredited laboratory that the Commission has accepted to perform the specific tests associated with each children’s product safety rule. For more details about what third party testing and certification means for your business, and for links to our list of accepted laboratories and sample certificates, please see our website at: www.cpsc.gov/3PT and www.cpsc.gov/labsearch.

Small Batch Manufacturers

In certain situations, qualifying small batch manufacturers may not be required to third party test their children's products in order to certify compliance with one particular group of children’s product safety rules. It depends on the children's product and the materials used to manufacture that children's product. Specific information on third party testing requirements for small batch manufacturers is available at www.cpsc.gov/smallbatch.

Sign-Up for Updates

For future updates on this and other regulatory issues that may affect you, consider signing up for one of our e-mail services. We have also just created an account on Twitter (@CPSCSmallBiz) and you can choose to follow us on Twitter for regular updates. The Small Business Ombudsman’s e-mail service sign-up form is at www.cpsc.gov/sbo on the upper right hand side of that Web page. And, at www.cpsc.gov/lists.html, you will also find a sign-up form for other useful Commission e-mail services of interest. Of course, if you have additional questions about these requirements, you may always contact me at www.cpsc.gov/sbo by clicking on the “Contact Form” on the upper right hand side of that Web page for the fastest response.

Please do not wait to take the necessary actions to ensure that your products comply and are properly third party tested and certified on January 1, 2012.

I hope that we can work together to ensure a robust compliance rate with these new requirements in order to protect consumers better and to ensure that businesses have a level playing field in providing safe and compliant consumer products to the American consumer.

Sincerely,

Neal S. Cohen
Small Business Ombudsman
U.S. Consumer Product Safety Commission
Tel: 301.504.7504
www.cpsc.gov/sbo
ncohen@cpsc.gov
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Renee Tice
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PostPosted: Tue Dec 06, 2011 9:21 am    Post subject: Small Batch Manufacturers - that's DEs! Reply with quote

Putting my own input here so as not to clutter the letter above.

I followed the link in the letter to the CPSC website to see the definition of Small Batch Manufacturer, and I think they've done a good job capturing DEs:

"What is a qualifying small batch manufacturer?


A small batch manufacturer is a qualifying small batch manufacturer if both of the following requirements are satisfied:

Income: A small batch manufacturer is defined as a manufacturer whose total gross revenues from the prior calendar year (e.g., calendar year 2011 sales to qualify for calendar year 2012) from the sale of all consumer products is $1 million or less. The term "consumer products" includes both children's products and non-children's products even though third party testing requirements apply only to children's products. It does not include revenues from non-consumer products, like food, drugs, and other items not regulated by the CPSC, but it does include revenues from the sale of consumer products by other businesses the registering company controls, is controlled by, or with which it is under common control.

Covered Product: A covered product means a consumer product manufactured by a small batch manufacturer where no more than 7,500 units of the same product were manufactured in the previous calendar year (i.e., calendar year 2011 sales for calendar year 2012 qualification.)"

I qualify for 2012 based on my 2011 numbers. The Covered Product thing isn't clear to me, though. Should I take that as a SKU, or a style number? I can absolutely see going over 7,500 units on a style number next year, which will mean third-party testing for the following year, I guess. For 2012, though, I still have to figure out what other means the CPSC will accept for confirming my product is under the total lead content and whether I need to be concerned about pthalates at all for my product type (pull-up cloth diapers for toddlers). I thought most fabrics were exempt from testing and that they were going to allow component testing, but if so that information is so buried I haven't found it yet.

Does anyone know more than I do? Are you issuing GCCs? What does one do with them if one sells direct to consumer instead of at wholesale?
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Esther
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PostPosted: Tue Dec 06, 2011 10:41 pm    Post subject: Reply with quote

This thing is still a mess. Honestly, I've been ignoring the CPSC for months. I hope the agency ends up on the Congressional spending cuts floor or some kind of self implosion. Too much to hope for, I know. I just see the CPSC, despite its honorable mission, marching to a political irrelevancy.

It makes me think of Atlas Shrugged, because that is where we are headed.
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Kathleen F.
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PostPosted: Wed Dec 07, 2011 11:34 am    Post subject: Reply with quote

I've also been ignoring it, it's a complete disaster. Tennebaum's a disaster, it's all political with little semblance of child safety at all.

If you sell consumer direct, you don't have to provide GCCs to them.
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Melissa Schworer
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PostPosted: Tue Mar 29, 2016 9:53 pm    Post subject: Tagging to look up on google later Reply with quote

Kathleen F. wrote:

If you sell consumer direct, you don't have to provide GCCs to them.


Tagging to look up on google later, because I don't understand the GCC thing yet.
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