As of Feb. 10, 2009, hair bows, tutu's, any type toy, craft, clothing piece, clippie, etc. handmade or not will not longer be legally able to be sold without a GCC (General Conformity Certificate). This certificate REQUIRES that every product that can be used by children under the age of 12 be tested for lead. (Phlhalates do not apply to hair bows as of now, but do to some products such as tutu's.)
I am not a lawyer, so I do not understand the full extent of this, but basically if you are selling without a GCC, it means HUGE fines. I'm talking $100,000. Despite thoughts on the contrary, your current inventory is not grandfathered in.
Obviously as bowmakers, we cannot afford to have all of our products tested and this, while meant to protect our children from large toy makers who were careless, will ultimately put small busnisses like myself and many of you out of business.
I read this forum on a regular basis for almost a year, but have never joined until now because with 2 small children I've never been a good emailer, much less blogger. However this is too important to let go and I've seen no mention of it anywhere here.
I don't want those of us who sell at Craft shows, market, or in boutiques to be blindsided and unprepared come Feburary. The restrictions get even harsher in August.
The good news is that the ones in Feb. , though they are a pain, are do-able. Getting products tested for lead at 600ppm via a source with an XRF maching can cost as little as $5 per test.
According to a lawyer/consultant I emailed regarding testing my products she said, "For items manufactured before 8/12/09, you can use XRF technology. The XRF technology needs to be part of a reasonable testing program - and it appears that at least one from each color/type of material would constitute a reasonable testing program. There isn't a lot of guidance on reasonable testing program - but it would seem that one of each material/yarn would be sufficient, provided that there was no further processing that would add lead. You will have to test the thread, joining materials, labels, tags, etc., too."
This is scary stuff. After 8/12 the cost will range from $300-$1000 per test. Why? Accredited labs according to the governement must fbe used as a 3rd party tester and XRF is no longer sufficient because the acceptable lead level drops to 300ppm so basically what that means is that more expensive equipment has to be used, thus costing you more. I'm not making these figures up, just using price quotes I've gotten and those from doing google searches.
I'm not trying to be scary or mean, but how on earth is a bow maker supposed to afford this? Not to mention that in August EVERY product has to have a tag attached to every item manufactured (And yes, we are considered manufacturers).
From the cpsc.gov website: Section 103(a) of the new law requires manufacturers to have a tracking label or other distinguishing permanent mark on any consumer product primarily intended for children twelve and younger. The tracking label must contain certain basic information, including the source of the product, the date of manufacture and more detailed information on the manufacturing process such as a batch or run number. The scope of this provision is quite broad in that it applies to all children’s products, including, but not limited to, items such as clothing or shoes not just toys and other regulated products. I''m still trying to figure out how this applies to hairbows, headbands, etc. But for those of us making handmade items as a small busniess, it is going to be, well fun it is not.
Here are a few great petitions (really you need to write your congressmen and senators): CPSIA Impacts on Children's Apparel Industry Petition : [ powered by iPetitions.com ] Save Handmade Toys & Children's Products from the CPSIA Petition : [ powered by iPetitions.com ]
Here are greatf blog posts to help you understand what I may unintentionally
be confusing on: Sassy Pink Boutique: CPSIA legislation
(This blog has a link that provides you with a predone letter and links to send to your congressmen and senators.) Fashion Incubator Blog Archive CPSIA and Small Manufacturers
Any help, suggestions on how you are coping with this would be useful!