What is the CPSC?
CPSC stands for the Consumer Product Safety Commission. The Commission has lead requirements for all children's products, along with other more product specific requirements regarding components and labeling. Third party testing is required unless you or the materials you use meet certain requirements, such as are set forth in the regulations and those set forth for Small Batch Manufacturers. The CPSIA is the act that gave the CPSC more regulatory and enforcement tools, as well as adding to several statutes.
Are you a Small Batch Manufacturer and what does that mean?
Yes, I have registered my business as a Small Batch Manufacturer. This means that, depending on the products I make, I am exempt from certain third-party testing requirements. However I must still certify that I take precautions to be compliant by ensuring that my children's products are made with compliant materials.
Tell me some more about testing requirements.
Under CPSC regulations, natural fibers and items are exempt from testing for lead. Extensive testing has revealed that the processes used for making textiles from these materials does not involve lead. This means that the cotton materials I use do not require testing as the process to create them has been deemed safe. Materials such as polyester and nylon have also been extensively tested and are on the exempt materials list.
Snaps, zippers and PUL have to be tested for lead, BPA and phthalate content (where applicable and depending upon use), if they are going to be used on a children's product. You can apply for a Small Batch Manufacturer number with the CPSC, which allows you to use the manufacturer's certs.
Flammability testing is not required for plain surface textiles (smooth, woven and knit fabrics), as long as they are over 2.6 oz. per square yard. Sleepwear for children 9 months and younger has the same flammability requirements as regular clothing. Fabrics with pile (a fuzzy surface) do require flammability testing, if they are going to be used in children's clothing. Flannel and cotton velour are good examples of fabrics with pile.
None of my current finished products require third party testing because they are made from natural fibers, not wearing apparel, or are not considered a children's item (wet bags). Hats are not considered wearing apparel. When I made wooden teethers, they were tested at a CPSC approved lab.
What materials do you use?
I use 100% organic cotton fabric, with exception of PUL lining for wet bags, that is considered plain surface textile. More information about the other materials I use can be found below:
Organic Cotton Interlock and Rib Knit: Exempt from flammability (plain-surfaced and over 2.6 ounces) and lead (natural fiber)
Organic Cotton Poplin: Exempt from flammability (plain-surfaced and over 2.6 ounces) and lead (natural fiber)
Organic Cotton Sherpa: Exempt from flammability (not used for clothing) and lead (natural fiber)
Organic cotton bodysuit blanks: Fabric is exempt from lead and flammability, snaps meet CPSC lead standards, statement on file
Resin snaps: Meet CPSC lead and pthalates standards, certs are on file
PUL (polyurethane laminate): Not used in children's products but meets CPSC lead, pthalate and BPA standards, certs/statement on file
Zippers: Not used in children's products but do meet CPSC requirements for lead, statement of compliance
Elastic: Exempt from lead due to fiber composition and being completely hidden
Cellulose crinkle material: Exempt due to composition and being completely hidden
How can I know if a small business meets CPSC safety requirements?
All you need to do is ask :) Most businesses will have a statement on their website, or listings, that says, "Meets CPSC Safety Requirements," though it is NOT required. They may have a statement page, like this one.
There are also special labeling requirements which vary from item to item. All children's products must have the following on their permanently attached label(s), with the exception of items that are very small or, in some cases, reversible. If the item is too small, the information may be placed on a hang tag or the packaging. Care labels are only required for wearing apparel:
Who the manufacturer is (usually this is a business logo with name)
How to contact the manufacturer (usually a website or email address)
Where the manufacturer creates the product (City & State) - though customs requires country as well
When the product was finished (often included in batch ID)
Fiber content (only required for certain items and not required to be permanently attached)
How to care for the product (only required to be permanently attached on wearing apparel)
A unique mark or number (batch ID) so you are able to follow recall instructions should the occasion arise.
You can find more information by following these links:
Last updated 07/24/2020