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Old 12-08-2008, 10:57
abunchofbows abunchofbows is offline
Senior Member
Join Date: May 2008
Posts: 98
Default Re: Attention To All!

I have been doing lots of reading of forums, articles, and scouring the CPSIA and CPSC website for more insight into this. I have decided that the legislation if still very vague and there is not an appropriate plan in place to enforce it yet.
1. There are only 14 (FOURTEEN) accredited labs in the United States that can test for lead at this time. Imagine those 14 labs having to test every single product.

2. The CPSCIA does not affect resale shops, consigment shops, garage sales etc as far as I can tell. Only MANUFACTURERS AND PRIVATE LABELERS are required to get third party testing.

3. I have inquired about what constitutes a manufacturer and private labeler with the CPSC. Generally, manufacturing refers to making of raw materials and ASSEMBLING refers to putting together products in final form. There are companies that only manufacture, others that manufacture and assemble, some only assemble, and some only sell whether wholesale or retail. The wording states that the manufacturer must provide proof to the wholesale or retail company. So there is that question of what the CPSC constitutes as a manufacturer.

Once I have more information on the definition of a manufacturer I will post. I believe that most of us crafters are "assemblers" and not manufacturers, and thus would be exempt from the testing. However, I am not sitting well with this until I know for sure.

Just my thoughts.

Last edited by abunchofbows; 12-08-2008 at 11:07.
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