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CPSIA FAQ 2
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Q1: Does packaging, including polybags and the bands that wrap around socks, require CPSIA compliance?
A1: The CPSIA does not apply to packaging, unless the packaging is intended for re-use. Polybags and bands wrapped around socks are discarded once the package is opened, so these do not fall under the scope of CPSIA. However, such packaging is subject to the Model Toxics in Packaging Legislation which limits the amounts of four heavy metals (lead, mercury, and cadmium and hexavalent chromium) in packaging. Our laboratories have the analytical expertise to test products to ensure that their packaging complies with these requirements.

Q2: Is flammability testing required for socks?
A2: The 16 CFR 1610 flammability regulation applies to all fabrics used in wearing apparel for both children and adults. Socks are typically exempt from flammability testing by reason of their fiber content or weight (if plain surface). Some lightweight socks, pantyhose or knee-highs, etc., would require flame testing.

Q3: Some tote bags and backpacks are clearly marketed to children and others clearly are not. Some people purchase backpacks for children that are not made or intended specifically for children but are used by them for school. Would these be considered children’s products? How do you draw the line in terms of what is a children’s product for these types of items?
A3: If intended for use by children, tote bags and backpacks need to meet CPSIA requirements. Adult backpacks that children may use are not subject to CPSIA requirements. How and where an item is marketed—location in a store, graphics, advertising, whether a child is shown using the item in an advertisement or on a label, etc.—all need to be considered in making the determination of whether the product is intended for a child.

Q4: Are the United States Virgin Islands and Puerto Rico subject to CPSIA regulations?
A4: Yes, the United States Virgin Islands and Puerto Rico are protected by the laws of the Consumer Product Safety Commission and are therefore subject to CPSIA regulations.

Q5: Do children’s products which are not toys need to be tested and labeled for small parts?
A5: No, 16 CFR 1500.19 applies only to toys and games.

Q6: I understand that several pieces of federal legislation have been introduced in the months following enactment of the CPSIA and that these proposals are aimed at amending various aspects of the CPSIA. What is the status of these proposals?
A6: HR 2715 is the legislation that passed and has been enacted. It provides a common sense approach to CPSIA compliance and testing. We are carefully monitoring the status of additional proposals, and we will report any significant developments that occur through our Monitor newsletter and News Alerts.

Q7: What are the standards for promotional give-away items that are for promotional use only—items that will be produced one time only and not on an ongoing basis and which are not for resale?
A7: Promotional items are not excluded from CPSIA requirements. Any promotional children’s products would be subject to the lead in surface coatings and lead in substrates requirements under CPSIA, along with tracking label requirements. If they are toys, they would also be subject to ASTM F 963 as well as to the phthalates limits. If they are child-care articles, those, too, would be subject to the appropriate phthalates limits. With promotional items, it is important to make a determination of who the product is intended for. If it is intended for a child 12 years of age or younger, it will certainly fall under the scope of CPSIA.

Q8: When you indicated that children’s toys are only items that children use during play, does that mean that piggy banks and bookmarks are not considered children’s toys?
A8: Although piggy banks and bookmarks are not considered toys, they would be considered children’s products, if they are intended primarily for the use of children 12 years or age or younger. In this case, they would be subject to the lead in surface coatings and lead in substrates requirements under CPSIA as well as the tracking label requirement. It is certainly possible that a piggy bank could be considered a toy if it has play value or appeal, such as one with moving parts or sounds, but, in general, an ordinary piggy bank would not be considered a toy.

Q9: What can suppliers do with existing noncompliant products?
A9: The CPSC may prohibit a person from exporting noncompliant products to another country unless the importing country has notified the Commission that it will accept those products. With respect to disposal or destruction of such products, because jurisdictions have differing requirements, the CPSC generally advises that manufacturers and retailers check with their local governments regarding the disposal of hazardous substances. When destruction has been requested through a corrective action, the CPSC requests that it be allowed to witness the destruction or that it receive an affidavit and photographs of the destroyed items.

Q10: Which tests are required for toys, gifts, textiles and consumer electronics?
A10: There are many different tests and standards that apply to various categories of products. There isn’t really one list that can provide all the information, as testing done on toys is much different from that which is done on textiles or furniture. Not only does the testing vary for different categories of products, but it may vary based on the intended use of the product and on the age of the person for which the product is intended. As you can imagine, a list containing all of this information would be of considerable length. When a specific product is given to us for testing, we call upon our experts in that category to determine the appropriate testing.

Q11:How can I be assured that your lab is accredited by the CPSC to do child safety testing on our products?
A11: The CPSC lists accredited laboratories on its website. The CPSC does not issue accreditation documents or certificates to the individual labs. It simply provides this list of approved laboratories.

Q12: What about the packaging we use? Is that under the scope of CPSIA?
A12: Packaging that is intended to be discarded is not covered by the CPSIA. There is state legislation which addresses requirements for heavy metals in packaging. If the packaging is not intended to be discarded and is considered part of the product, such as a storage bag for children’s blocks, it needs to comply with the CPSIA requirements.

Q13: Do the CPSIA requirements apply to school publishing products that are sold directly to schools or school systems?
A13: The definition of consumer product includes items that are intended to be used in or around a school, and children’s products are, by definition, consumer products intended for children 12 years of age or younger. Therefore, these products would fall under the scope of the CPSIA and would need to comply with its requirements.

Q14: How does the CPSIA apply to manufacturers using certified organic components, for example, fabric?
A14: The law does not differentiate between certified organic components and other materials. The organic components would require compliance just as their non-organic counterparts would. They would also be entitled to the same exclusions, lead and phthalates, for example, for fabric.

Q15: How does the new law apply to small domestic manufacturers of handmade items? Have there been any exceptions made for small producers?
A15: Small batch manufacturers may register on CPSC’s Small Batch Manufacturer Registry. While there are no exceptions for compliance, there are some exceptions to third-party testing. And the CPSC has said that for smaller, low-volume manufacturers, testing done every 10,000 units rather than on an annual basis is allowed. The CPSC does have a guide for small businesses, resellers, crafters, and charities which states that even someone working from home, making clothes and toys for children, must conform to the CPSIA.

Q16: How do you foresee the new changes in the law affecting research as a whole and, specifically, marketing research?
A16: There are some provisions in the Act that require studies or research to be performed. Section 107 requires a study of preventable injuries and deaths in minority children related to consumer products, Section 225 requires a study on the effectiveness of authorities relating to safety of imported consumer products, and Section 234 requires a study on the use of formaldehyde in manufacturing of textile and apparel articles. There is also the formation of the Chronic Hazard Advisory Panel (CHAP) to examine the health effects of phthalates. Marketing research may actually benefit from the CPSIA in that the Act provides for more transparency. The consumer registration requirements for Durable Nursery Products, the Tracking Labels provision, the Public Disclosure of Information and establishment of a publicly available consumer product safety information database will all provide information that may not have been readily available in the past. There is a requirement for identification of the supply chain (upon CPSC request), and the recall notices themselves require more detailed information such as name of significant retailers of the product, number of injuries and deaths caused by the product, the ages of the persons injured or killed, and the dates when the Commission received such information about the injuries or deaths.

Q17: Have there been any changes to product hazard reporting requirements, and how will the new Consumer Product Safety Database be operated?
A17: These topics are covered in Title II of the CPSIA. Section 214 of the CPSIA provides the CPSC with enhanced recall authority and requires an automatic report for failures to comply with a rule under ANY of the Federal Acts. It also gives CPSC the authority to mandate the Corrective Action Plan for mandatory recalls, and adds two new requirements for inclusion in the recall notice, the names of significant retailers of the product, and details on injuries and deaths caused by the product. CPSC has also announced new Section 15 reporting features. You can now get an acknowledgement and exact copy of a Section 15 report you file with the CPSC’s Office of Compliance through its web-based portal. This provides you with an official record that the report has been received by CPSC staff. The online reporting form has also been modified to allow the entry of multiple manufacturers and component part manufacturers. With regards to the Public Consumer Product Safety Database, Section 212 of the CPSIA, this launched in March 2011. Essentially consumers can file reports about products that other people could see before purchasing a new item. Manufacturers should register at www.SaferProducts.gov, and the CPSC sends any complaint or concern to the manufacturer within five business days of its receipt, and that the manufacturer has 10 business days to respond. Manufacturers can request that confidential information not be included in the public database and can also request that their comments be included. It is also possible to remove or modify a product safety complaint or concern even after it has been posted.

Q18: How can I learn more about the new requirements for CPSIA?
A18: To receive free email alerts about the CPSIA, you can add your name to the CPSC’s CPSIA subscription list. By signing up for this service, each time a new CPSIA entry is posted to the CPSC website, an automatic email notification is sent directly to you.

- CPSC Home Page
- CPSC’s CPSIA Web Page
- CPSC’s CPSIA Frequently Asked Questions
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