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Old 12-14-2008, 03:09
HotBowMom HotBowMom is offline
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Join Date: Oct 2008
Posts: 248
Default Re: Attention To All!

Creative, section 104 refers to the pthlates (sp?) testing, not lead. Bow makers and the rest of us homecrafters don't have to worry since, for the most part, our products don't contain plastics.

It is section 101, the lead testing provision, that is requiring testing off ALL children's products. The CPSC has just released a few new FAQS to check out:

The very first item on the list of definitions has to do with what constitues a children's product:

Definition of Children’s Product
: What is the definition of a children's product and how will the age cutoffs be

: A “children’s product” means a consumer product designed or intended primarily for
children 12 years of age or younger. In determining whether a consumer product is primarily
intended for a child 12 years of age or younger, the following factors will be considered:

A statement by the manufacturer about the intended use of the product, including
a label on the product if such statement is reasonable.

Whether the product is represented in its packaging, display, promotion or
advertising as appropriate for use by children 12 years of age or younger.

Whether the product is commonly recognized by consumers as being intended for
use by a child 12 years of age or younger.

The Age Determination Guidelines issued by the Commission staff in September

2002, and any successor to such guidelines."

Now, if you go back to section 101, you will see the CPSA talking about ALL children's products needing to be tested for lead levels.

Here is another great link to the CPSIA regarding the new standards:

Frequently Asked Questions on the Consumer Product Safety Improvement Act (CPSIA)

Again, you need to see a lawyer who specializes in product safety and sit down and tell them your product and how do you need to comply with the law.
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