How will the Consumer Product Safety Improvement Act affect you?
By Alison Brownrigg
NWsource shopping columnist
Last year, in response to the deluge of imported Chinese toys laced with high levels of lead, the Senate and Congress overwhelmingly passed the Consumer Product Safety Improvement Act (CPSIA). Meant to apply more stringent safety measures for new products intended for children under the age of 12, CPSIA, which goes into effect on Feb. 10, has some unintended consequences for makers of handmade toys, clothing of all kinds, paper goods, resellers and consignment shops.
In order to comply with the new law, all domestic manufacturers of these goods must provide proof of third-party testing to certify that they contain less than 600 parts per million (ppm) total lead and less than 0.1% of certain specific phthalates or face prison time or penalties of $100,000 per incident. This testing can cost between $75 and $4,000 per item. While big corporations (like Mattel and Hasbro) can absorb those costs, an expense like that will effectively put small companies out of business.
A recent press release from the Consumer Product Safety Commission (CPSC) regarding resellers and consignment stores clarifies the law like this: “Sellers of used children’s products, such as thrift stores and consignment stores, are not required to certify that those products meet the new lead limits, phthalates standard or new toy standards." However, it’s still illegal to sell products that contain more than the legal limit of lead and pthalates, so how are resellers to know they're in compliance unless they perform the testing? Additionally, the CPSC clarified that the law applies to reselling items manufactured prior to the Feb. 10 date, leaving many of these stores with inventory that they can’t sell. There is some discussion about exempting items made from natural materials, like undyed wood and cotton, but no changes have been made to the law at this point.
I think we can all agree that lead and other harmful chemical levels in our children’s toys needs serious attention and stringent monitoring. But what this law neglects to address are the small businesses who sell stuff for kids, like Buggy and Childish Things, and designers like Kristin Loffer Theiss, who makes plush toys and mobiles out of wool felt and cotton.
I’m curious to hear what you think about this issue. Will it affect you? Do you agree with Washington Public Interest Research Group (WashPIRG), which thinks that the law is fine the way it is and that all products made for children should be tested for lead? Or do you agree with groups like the Handmade Toy Alliance that the law should be modified?
P.S. Please make your comments on this page and not to my e-mail address so that we can all benefit from your opinions. Thanks.
Hit me with your best shop: alisonbrownrigg@gmail.com
Copyright © 2009 The Seattle Times Company

Comments
Post a commentThis law had good intentions, but horrible unintended (I am sure) consequences. Rep. Henry Waxman can call a hearing (but hasn't yet, even after numerous representatives, the CPSC and members of the public have asked him to do so) on the implementation of this law so that the impact on small business can be discussed and perhaps the implementation date changed so that all the things that should have been thought about BEFORE the law was passed can be discussed. At this point, I see this law as a horrible failure of Congress to fully understand and think through the implications of their actions. Please contact Rep. Waxman and encourage him to call for a hearing on this bill prior to the implementation date.
I have spent years of my life writing and illustrating children's books which are published by a small publishing company. These testing costs would be prohibitive. My books are healthily-ever-after children's books to encourage our children to do all the things we want them to to stay healthy and fit.
How would this affect me? It would be devastating if it remains as written. But let's put my hard work and passion aside.
I'm also a teacher. As the law is written, (correct me if I'm wrong), all of our books in the school would also have to go through this.
We really wouldn't be able to have books in schools at all after Feb. 10. Is this ludicrous? Think about what is in a primary classroom besides books: toys, manipulatives, and more.
I am a small business owner of collectibles which include toys and children's books. If I am interpreting the law correctly, it will mean that thousands of small businesses across the country that sell used children's items (and also non-profits that raise money for charities)will have to literally trash their entire inventory of clothes, toys, books, etc. I shudder to think of the environmental impact (landfills full of what will now be considered worthless goods that can't be sold or donated)? Add to that the economic consequences at the worst time possible? I certainly agree with protecting children from lead and dangerous products, but I think there needs to be some re-evaluation of the wording and implementation. Please, this is a potential nightmare for ALL of us!
Yes this does effect my baby clothing line. The cost of testing doesn't justify staying in business really. Many of us are hoping for change before August. Whether the law stays or changes something must be done. We need clarification. There is still a lot of unanswered questions. How do we move forward or make any further decisions if we don't know the answers.
I will lose my hair bow business, JenLynnDesigns.com as of 2/10/09 if the law is not changed. I understand that the sun will continue to rise and set without handmade clothing, toys and accessories for kids, but I, for one, will miss them dearly. They are the antidote to the mass-produced, plastic, toys and sexualized clothing styles for little girls that fill our malls and discount stores. My experience has found them to be made with high-quality materials and care. I find it ironic that the foreign-made, mass-produced products that caused the lead scare in the first place will be the only ones left in the marketplace once this law is implemented. Rep. Henry Waxman - (202) 225-3976 can call a hearing to address the problems. Everyone opposed should call him and demand that the 2/10/09 implementation date is pushed back until the issues are satisfactorily addressed.
If nothing is done to correct this well-meant but poorly written legislation, tens of thousands of small businesses will be forced to close, in an already dire economy. I have already lost significant advertising revenue from companies who aren't sure if they'll be in business a month from now.
Why is this looming disaster not being covered by all the major media?
The CPSIA law is one of the worst ever written. It is irresponsible, nonsensical, and threatens the livelihoods of many small businesses needlessly. Surely we can protect children without forcing thousands of businesses to close!
I'm part-owner of a specialty toy and children's book store. The impact of this law, if it is enacted as written and interpreted by the CPSC will be devastating.
My partner has spent the last three weeks personally contacting as many of our 300+ vendors as she can in an attempt to obtain documentation that the goods we currently have in our inventory comply with the February and August lead bans. While we are convinced that our inventory is indeed compliant, since the testing protocol was not in place at the time the goods were produced, many vendors simply do not have documentation that their products comply. It just does not exist! So we're faced with getting rid of tens of thousands of dollars in inventory before February 10.
It is u imperative that we make sure that the items our children use are safe. The intent of CPSIA is unassailable. The effects of the law, however, may well mean the end of many, many small businesses.
It sickens me that once again, children are the biggest victims of new well-meaning but ubsurdly horribly written policies and legislations. Children already have to deal with losing art class, recess and PE which were a fresh releif for most kids from the tedium of sitting at a desk all day listening to the teacher lecture.
The element of this that scares me the most is the fact that in children's lives today, creativity, imagination and critical thinking are disappearing. Our children are not being challenged enough, shown effection enough, or pushed hard enough in schools today. And a lot of parents rely on quality, creative hand-made toys and other products to give their children the imagination that is so lacking in our school systems.
I have started a blog that addresses the issue of needing to bring these qualities back into our child's lives. Please share your comments with me and other bloggers that are writing about similar topics.
www.buttonsnrainbows.blogspot.com
Congress did not consider where all these third-party labs were supposed to come from. The existing third-party labs already had plenty of business, and it's not the sort of operation you can start up over night. This isn't just about toys or retailers, by the way. Every single zipper or button in a kid's garment has to be certified.
i can't possibly get my mind around the thought process that brought about this law and these amendments - yes i understand completely that the safety of children MUST and should come first but the language of this law is so poorly written and so unbelievably broad that it absolutely boggles my mind. the far reaching economic ramifications of this are only scratched at the surface when you consider the handmade toy and baby product industries - this law will effect millions of people both directly and indirectly. the CPSIA law is doing more harm than good. please write to your congressmen & women and tell them this law needs a complete overhaul so that it's true intent of keeping children safe can be realized - https://writerep.house.gov/writerep/welcome.shtml
www.myminimocs.com
I am very passionate about this topic.
I don't know what the CPSC was drinking the day this law was written, but it couldn't have been good.
This law, if it stays as is, will destroy the small business world faster than a speeding bullet. I want to give you an example of what the general public doesn't get or knows about the cost of EACH item a seller will have to spend to get it considered "Legal" to sell.
If I were to test a bib in my store, which has 5 components, here are the costs to me:
5 components for lead testing at $70 each it will cost me $350.
5 components for phthalates (a softner for plastics) testing at $350 it will cost me $1700.
The complete cost to test a bib is $2100.
The custom bib, which I sell for $10, will now sell for $2110.
Enjoy your new world of baby items thanks to the CPSC!
I own a girl's clothing line. This law is great in intention but very misguided in implementation. It is not industry specific which is what is blatantly overlooked by the law makers. For the apparel industry, an industry that has not had any incidents of lead poisoning (through textiles - CDC has not 1 reported case), we have to prove that our inherently safe products are safe. As a small business, manufacturing my goods in Los Angeles CA, I am testing my products at great cost. However, what I feel would be reasonable is testing my products at different intervals of production every 3-6 months depending on how often materials change. I would love to see the law be amended to allow apparel manufacturers to test the materials instead of the finished products as many of our products use the same fabrics. There are ways to use the law to benefit everyone. I don't believe any manufacturer for children's products wants to make things that are harmful to the very customer who will be using our products. Yes, the testing costs are ultimately passed onto the consumer but that's the price we pay to have our goods made well. I'm keeping my business in USA - I just need the USA to support my efforts.
Thank you.
This law as it stands affects us on a global scale. From the consumer to the business owners. Children for whom this law was written to protect ultimately be the ones to suffer. They are facing bans from libraries, to bans on creativity.
As a business owner of handmade products, our POSH Pads are going to be hit indirectly. We have our products in boutiques around the country. These small shops carry speciality items, OOAK one of a kind handmade clothing, accessories and toys. Alot of these shops will be forced to close if a majority of their inventory is seen as "toxic" waste. So we will then be hit with lose of distribution.
We need people to call and write, send something handmade and beautiful before the deadline this Friday Jan. 30th. Don't wait and hope that someone else will call or write.
The unimaginable can and will happen if we don't speak up. Keep calling and writing everday this week. The economic burden is upon not only us but them.
~Robyn and Jessica
MyPoshPads.com
Well there goes pretty much the ENTIRE cloth diaper community (which is almost completely made up of small businesses and WAHMs).
...Including my company, in which I sell handmade cloth diapers.
I was looking forward to coming out with a one-sized diaper, but I guess that's gone with the wind now. Fantastic.
We began our wood toy business in 1976, selling at art and craft shows. The internet came and made national sales possible. With the China recalls in 2007, our business has experienced "explosive growth". Customers are constantly thanking us for providing "Made in America" toys for their children.
Now we are facing closure due to $2700 per item batch to prove there is no lead or phaletes in our wood toys - this is per year or per batch. We make our toys in no more than 5-10 per batch.
How crazy is this?
It's interesting that the problem started with Mattel's poor management of their Chinese factories and when this is over and done they and their ilk will be the only ones left in business. To get lead poisoning you have to ingest the product. If you have a 12 year old that is chewing on his shoes, you have a bigger problem than potential lead poisoning. This act is another knee jerk reaction to voter complaints. What's next, are we going to tear down all of the old buildings containing lead paint and pipes? When are voters going to learn that passing parental responsibility on to lawmakers is the dumbest way to get a sensible solution. I have a small online business that sells stuffed animals mfg by Gund. When Mattel had the problem, I contacted Gund and was advised that they have always done their own testing and had not had a problem. However, the way this act reads, I will be required to test my existing inventory. Since, that would be cost prohibitive, my only recourse will be to dispose of the inventory because the testing would cost than the value of the inventory. Here's a thought, if we really want to protect the children, let's clean up our air.
I am an at home mom and I will no longer be able to sell my handmade cloth crayon holders due to this law. My crayon holders only hold "Crayola" Crayons and are made of cloth, thread and wide ribbon sewn tight.
I also create childrens soap from a natural soap base, and the fragrances I use are already "phthalate" free. I will no longer be able to market my soaps for children, who are in desperate need of safe bath products.
So let me get this straight...China imports unsafe products and we the "local" artisans, get the ax? Land of the Free? I think not...
Add me to the list - my home-based business is also on the chopping block and I am scrambling. It took me 6 years to build my little company, so I won't let it go without a fight.
I am trying to find a "reasonable testing program" that is acceptable to the CPSC, and will allow me to continue making my handmade children's items after Feb. 10. Reasonable testing??? Even this one point is unclear. I've read and re-read so much about this issue, but the law itself is impossible for me to understand. I plan to contact an attorney to help me interpret the rules:
1. is "reasonable testing" even allowed?
2. is XRF testing an acceptable method?
3. if so, how long is it valid?
4. what documentation is required?
5. what about product labeling?
Every question leads to another. For many of us I'm sure, the legal fees alone will be too much to pursue this.
I have been in touch with Environmental Services & Solutions Corporation (http://www.essco-safetycheck.com), a Seattle-area company that performs XRF testing for lead. They are well aware of the CPSIA and are trying to raise awareness with congress about this issue. Hopefully, this more affordable method of testing will be acceptable and will allow me to stay in business after Feb 10. If nothing else, to buy me time until August.
I urge you all to keep fighting. Keep reading blogs and forums. Here's a good one: http://www.fashion-incubator.com/
Stay informed. Keep talking to everyone you know about it. We just can't let this happen.
~ Vickie Erlandsen
www.dillyhearts.com
We already have laws- many laws on the books against lead. This was brought about by imports from China- why are American made businesses paying the price for it? Why is the American consumer paying the price for it? Why are kids paying the price for it? This law is knee-jerk to the extreme and must be repealed or at least rewritten with at least a streak of common sense.
It's like telling a farmer he must get every bushel of corn tested for marijuana so we can keep our children safe even though laws are already in place against it.
Is there some problem in American made businesses with lead we don't know about?
If this is the platform for testing, why not expand it? For example test for all known toxins on any product made or sold for any age group regardless of the laws already in place. We would be extra, extra, extra,extra safe then right? Wrong!
I have been designing and selling doll clothing and accessories for girls for the past 13 years. In the beginning, it was a way to make money at home while my children were growing up. With the internet, my little hobby turned into an actual business, with dreams of expanding and creating my own doll manufactured here in the US. And then this happened. I'm sitting on lots of inventory I'll never be able to sell, let alone give away. My husband is facing a lay off in June. I had always thought of my ability to sew as a real asset. I could always make money doing this. And now, with this impossible to comply with regulation, my only means of providing for my family has just been destroyed. Is this still America? Why are my things, which never hurt anyone, now going to be illegal. I'm not just mad. I'm afraid. Very afraid. And everyone else should be, too. This is what happens with over regulation, my friends.
Not only will this law shut down small business owners, but it also kills off budding entrepreneurs. I was laid off a few months ago and was planning on starting my own business in the children's industry. I guess there's no way I can afford to do this now.
This law also indirectly turns anything adults own that would fall under the Act into worthless garbage. Anything you've been fortunate enough to collect since childhood or inherit from a family member is now junk and worth nothing, nothing, nothing. There's not going to be any "antique" anything to be found for the under 13-age group if you want to add to an existing collection because it will all be in the landfills. A lot of our heritage and history will end up in the dump.
I would like to know where our BAILOUT will be, when thousands of small business come to a screaching halt. LOL We didn't take expensive business trips, spend 1.2 million decorating our office, borrow money we could not afford to pay back, pad our books or make products that people didn't want. WE are hard working people trying to eke out a living making quality OOAK handmade goods. Why do they find it so easy to throw us away? When did we stop being counted? I too will not go down without a fight. . . they can come rip the sewing machine from my hands. . . I dare them, S.
“Safety is an issue and they have to test. The law is the law.” These are the words I hear from consumers each day. By applying this statement, it would be reasonable to test anything for any substance regardless of the likelihood of lead content in 100% cotton.
Also, general consumers have no idea of the costs to test. For example, I found some testing quotes on the internet and ran those numbers to a box of 98 crayola crayons. The broken down cost to test per box of crayons was about $35. No every box does not need to be tested, just every color crayon, paper wrapping, box and shapener PER BATCH. Crayola makes 2400 crayons per batch, one color at a time. Testing only one box at that lab woul be - $86,136, but broken down through batches and colors it is about $35, this means that they have to sell the crayons for probably $70 a box, for wages, cost of production, shipping etc. Now add up a school supply list and still state with a straight face that the law is the law.
Closing Thoughts - The EPA estimates that drinking water can make up 20 percent or more of a person's total exposure to lead.
I'm sure many of you have already heard the news that the CPSIA mandatory testing has been suspended for a year so the law can be reviewed. More info here: http://blog.buyhandmade.org/?p=190.
I was 1 day away from making a $10,000 purchase of capital equipment to expand my mother-in-laws business to add a line of children's embroidered clothing, towels, blankets, hats etc. featuring her artwork when I found out about this law. I scrapped my business plan to expand her business and am now holding the money to help her with her living expenses. Her art business is her sole means of support and with the economy down her sales are off. While eventually my $10K will end up in the economy it will go to purchase food and pay heating bills not help keep people working. This law is (and already has) put people out of work at a time when we need to keep people working.
If you do not think this law affects you because you do not have children or grandchildren under 12 think again. Think about what a 2nd grader comes in contact with on a daily basis both at home and at school, the scope of products affected by this law becomes clear. Textbooks, paper, sports equipment, desks, pens, computers, lunch trays, dishes, you get the idea. Imagine how much it will now cost just to provide everything in an elementary school. The total will be staggering and it will all come out of your pocket as a taxpayer.
@Alison:
The testing requirement has been suspended, but that basically doesn't change anything.
The law is still in effect (as of 1/10/09). If you sell something exceeding the limits, you are a criminal, and a felon I believe. How can you be sure you aren't violating the law if you don't test?
On the 10th, there will be no children allowed in libraries, or able to have a school textbook. Everything on the shelves at secondhand stores or new will still have to be taken to the landfill.
*sigh*
I just found this article and wanted to share WashPIRG's position on the application of the Consumer Product Safety Improvement Act (CPSIA).
Congress gave the Consumer Product Safety Commission the authority to clarify the CPSIA and make necessary changes, exemptions, etc. The CPSC has issued a few key rulings, including exempting thrift stores from having to certify the products in their stores and exempting natural materials like wood, cotton, etc. from the testing requirements.
However, the CPSC needs to do a better job of clarifying the law and making sure retailers and manufacturers know what their responsibilities are under the new standards. There is a lot of misinformation as to the impact this could have on small business. To be clear the testing requirements outlined in the CPSIA do not apply to retailers. Only manufacturers are required to test products. Second hand stores have been exempted from the testing requirements. On December 24, 2008,
CPSC began the rulemaking that would exclude from the regulation certain natural, non-dyed materials such as precious gemstones, wood, cotton, silk, wool, hemp, flax and linen as well as certain metal alloys. This means that products made of these natural materials – without dyes or
paints – would be excluded from the certification requirement. Pre-approved dyes and paints are expected to be on the market later this year. What this means is that many of the small manufacturers mentioned in articles like this won't be required to do much, if any, testing.
The CPSC also needs to do what it can to help businesses comply with the law, including providing information that will more easily facilitate third party testing. (By the way, the estimates provided by the Handmade Toy Alliance are way overblown. Our own survey of third party testing facilities indicates that U.S. laboratories charge $50 to test for lead.)
WashPIRG has repeatedly asked the CPSC to further clarify the law and ease implementation. Instead, what we get a one year delay on the implementation of the lead standards. This is unacceptable. While certain exemptions may be necessary to ease implementation, no exemptions should be given unless they are scientifically well supported to have no impact on children's health. The safety of our kids overrides every other concern.
The CPSIA is based on a fundamental principal that products must be tested for safety before they are sold. Before the bill was passed, no testing was required and too many products were on store shelves that were harmful to consumers and violated mandatory and voluntary safety
standards. This situation lead to terrible results- toys with lead paint, children’s metal jewelry made primarily from lead, cribs that break and cause strangulation and suffocation, and magnets that when swallowed in multiples can rip through intestines.
Any exception or exclusion from testing requirements, as included in the CPSIA must be based on the principle that the product will not harm consumers by causing the absorption of lead. The provisions in this law requiring third party testing of children’s products subject to mandatory
standards are included to protect the public and especially children from unsafe products.
Blair Anundson
WashPIRG Consumer Advocate
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