Are infant winter boots exempt?

[Susan Mann]

So, I am hoping to start manufacturing infant winter boots and slippers. I started reading up on CPSIA and ran very quickly into § 1610.1 (c) (3) which states:

Specific exceptions. This standard shall not apply to: .....
(3) Footwear, provided it does not consist of hosiery in whole or part and is not affixed to or does not form an integral part of another garment;

So, does that mean my products are exempt? How do I interpret that. I do use cord locks, which could be a small part hazard. So I'm really not sure what I'm supposed to do.

I am applying for a small batch exemption in the mean time anyway.

Susan Mann

[Susan Mann]

Sorry to post to my post. But I'm, trying to figure this all out. So I think my understanding is that the boots are exempt from flammability tests but any components (grommets, d-rings, cord locks etc) aren't and specifically need to be lead and phthalate free. And that if I register for small batch exemption then I need certificates from my suppliers that the components are lead and phthalate free.
Am I on the right track here?

And finally - does small batch exemption extend to tracking/monitoring/labelling?

[Kathleen F.]

I'm not sure. Footwear was largely exempt because the cpsc backed down from the assertion that kids would be sucking on shoelace eyelets (that is, when they weren't sucking on their bicycle spokes). Cord locks could be another issue. Other than that it is a possible choking hazard (but not if they can't be separated), it could be an issue because children will or may touch those. So if cord locks have lead or phthalates, you'll need to find a supplier who can provide testing certification results to you.
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[Esther]

Footwear is another Catch-22 with the law. It may be helpful to review past recalls to see what kinds of things cause problems and what the CPSC may look at in the future.