XQ Manufacturing Group Blog

CPSIA (Consumer Product Safety Improvement Act) and our China Manufactured Product
For those of you unclear about compliance with the developing changes to the recent CPSIA law, join the club. In December of 2009 Congress and the Consumer Product Safety Commission announced new aspects effecting standards, enforcement and delays in enforcement. Here is our summary of what you need to know as it stands at the moment.
Labeling – all products primarily intended for kids 12 and under should have a pertinent label on the packaging and internally that includes the following:
Date of production, a Batch or lot number for tracking purposes, information to identify the manufacturer or the importer (RN number or business name), information of manufacturer (this may be an internal ID number so as not to unecessarily disclose unnecessary information to clients), location info (beyond the standard ‘Made in China’ label it appears standard practice will become adding a city name).
Clothing items much carry labels while some other products may be exempt from inner labeling if labeling the item is not practical such as wooden blocks.
A General Certificate of Conformity issued by the importer declaring the product confirms to current standards will be required with import paperwork for children’s products. A summary of the form and what it must include is here http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf. Currently, certain high risk children’s products such as cribs must have accompanying 3rd party testing certification, while commonplace items such as toys and clothing do not need 3rd party certification with some exceptions such as children’s jewelery and surface paint lead tests (not to be confused with overall lead content testing). General testing catagories and a list of CPSA qualified testing labs can be found here http://www.cpsc.gov/cgi-bin/labapplist.aspx. Regardless of testing certification the importer is still liable that the products meet product safety standards such as overall lead content or phthalates in plastic or plasticol screen printing inks. This combined with the fact that many retailers now require such certification regardless of delays in enforcement of this policy, we recommend component testing for all elements of children’s clothing. Most of the ink lines we screen print with already have existing documentation on their lead content. The CPSIA has recognized that most fabrics such as cotton do not have a risk of any lead content and thus may be exempt from testing on a long term basis.

The CPSIA is still a work in progress and each product designed for Children 12 and under needs to be individually examined to evaluate potential CPSIA conformity. As a manufacturer we strive to work ahead of the changes in this law and protect our customers from any unseen vulnerabilities. Please feel free to ask how we can help with CPSIA compliance in your next project.