Thursday, January 8, 2009

Okay, I know I'm getting B-O-R-I-N-G... but one more thing

This is what you get for reading the blog of an opinionated woman :)

Here's a Press Release I finally discovered today (thanks to another concerned crafter) that has to do with the certification requirements. Now, I might be reading this optimistically, but I think this might be good. See what you think:


CPSC Clarifies Certification Requirements
Agency Staff to Focus on Compliance with Safety Rules

WASHINGTON, D. C. – On Monday, November 10, the U.S. Consumer Product Safety Commission (CPSC) issued a final rule (pdf) by unanimous vote, addressing the conformity certification required for consumer products subject to safety rules under CPSC jurisdiction.

The Commission addressed three major issues: 1) who should supply the certificate; 2) how the certificate can be filed; and 3) CPSC enforcement of general certification.

First, the certification process will now be streamlined, by limiting the number of parties who must issue conformity certifications unless a preexisting Commission product standard requires otherwise. The Commission determined that for imported products, only the importer needs to issue the conformity certificate.

Foreign manufacturers and private labelers of imported products do not need to issue certificates, and they do not need to be listed as parties on certificates. For products manufactured in the United States, only the domestic manufacturer needs to issue the certificate. Private labelers do not need to issue certificates, and do not need to be listed as parties on certificates.

Second, the rule confirms that electronic means can be used to meet the certification requirement in the Consumer Product Safety Improvements Act of 2008 (CPSIA) and that conformity certifications can accompany the product and be furnished to distributors and retailers by a variety of electronic means. Electronic certificates can also be posted on a website for inspection or included with other electronic documents accompanying shipments through Customs, so long as the certificates can be produced immediately for inspection.

Finally, the agency intends to focus its enforcement efforts on a product’s compliance with our safety requirements. While the Commission recognizes that every company is expected to make its best efforts to comply promptly with the new certificate requirements, the agency intends initially to focus more on compliance with the safety rules underlying the certificate, rather than on the certificate or form of the certificate itself. For addition information and a copy of the rule, go to

My Interpretation:
As a "private labeler" I am not personally responsible for testing my materials. Manufacturers and importers are responsible for testing to make sure lead and other metals fall within the new standards. (Sound like a rant you've read anywhere nearby?) They are responsible for providing certification that their items have been tested and are within standards.
The hiccup -- I cannot necessarily continue using my current suppliers. Ribbon, alligator style hair clips, etc. are not automatically required to be tested unless the item itself qualifies as a children's item. I will still have to make sure that my suppliers have conformity certificates and that my final products will be safe for children. I'm okay with that. I have been doing a lot of research (obviously -- otherwise I wouldn't bore y'all so much) and have started finding suppliers that are already preparing for the full implementation of this law. My costs will probably go up, but I will be able to stand by my product as being safe and legal as far as I understand the law.

I think I'm done boring you now. I PROMISE that my next post will be cute, fun, and full of pictures :) Stay tuned!


ems said...

Good News!!! I hope it all works out. I was getting so bugged about the whole situation when I read your other posts. I'm glad to hear that it may not affect you too much!

Corilee said...

If your anger is in any way tied up to the length of your post, you must have been really, REALLY angry about it, LOL. I don't blame you.... and they want to have the government take over the health care industry. gasp! We'll all die by the time they get it anywhere near right.

Tilly's Bowtique said...

LOL, if I tied my anger and frustration to the length of the blog... yeah, I'd still be typing :P I have recently emailed our senators as well as local news desks. This thing is ridiculous. I'm up to an 8 page file of correspondence I'm sending out!