Compliance

What is CPSC and CPSIA?
CPSC stands for the Consumer Product Safety Commission; the purpose of the CPSC is to “protect the public against unreasonable risks of injuries and deaths associated with consumer products”.  Simply put, it is a government agency which ensures the products we purchase are safe for use. The CPSIA — Consumer Product Safety Improvement Act — is the act that gave the CPSC more regulatory and enforcement tools, as well as adding to several statutes directing manufacturing practices.

What does the CPSC require for children’s products?
Children’s products have more regulations than items geared towards adults. The Commission’s regulations require products sold to children under the age of 13 comply with safety rules (be free of lead and phthalates, and meet certain flammability standards), be tested for compliance, maintain a written record of compliance on file, and have permanent tracking information affixed to the item.  After the enactment of the CPSIA, some testing provisions were granted to Small Batch Manufacturers to obtain relief from third party compliance testing.

Are you a Small Batch Manufacturer and what does that mean?
Yes, I have registered Stitch To Stitch as a Small Batch Manufacturer.  This means that because of the size of my operation, while all precautions are still taken for my items to be compliant, I am exempt from needing the finished product tested by a third party.  For every item produced, there is a Certificate of Product Conformity (CPC) on file to document compliance. This helps to keep production costs down when working on a small scale.

What are the CPSC testing requirements for raw materials?
As stated above, the Commission’s regulations require products sold to children under the age of 13 be free of lead and phthalates, and meet certain flammability standards. Because of the testing provisions granted to Small Batch Manufacturers, all materials used must be compliant in order to produce a safe, compliant, finished product.

Under CPSC regulations, textiles consisting of natural and some manufactured fibers are exempt from testing for lead and/or phthalates.  Extensive research has revealed the processes used for making these textiles does not involve lead or phthalates, so they are naturally lead/phthalate free.  This means that the cotton fabrics and synthetic trims (lace, ribbon, etc.) I use do not require testing as the process to create them has been deemed safe.

Due to the nature of the items, snaps, buttons, and tie hardware have to be tested for lead and phthalate content (where applicable). I purchase all of these items from suppliers that have already performed this testing; their test results are kept on file along with the CPC for the finished item.

Flammability testing is not required for plain surface textiles (smooth, woven fabrics) over 2.6 oz. per square yard, some entirely synthetic textiles (acrylic, nylon, polyester), any material less than 2″ in width (lace, ribbon), and materials not exposed to air.  Fabrics with a pile/nap do require flammability testing, which is why all corduroy items are no longer available for purchase. At this point I have not been able to find a supplier who performs the flammability testing; to test myself is cost-prohibitive at this time.

What materials do you use?
All of the fabric currently used for Stitch To Stitch items is considered plain surface textiles and exempt from lead and flammability testing.

More information about the other materials used can be found below:

  • KAM Snaps: meets CPSC lead and phthalates standards, certificate of compliance is on file
  • Riley Blake Buttons:  meets CPSC lead and phthalates standards, certificate of compliance is on file
  • Sophia’s 12mm Buttons: meets CPSC lead and phthalates standards, certificate of compliance is on file
  • 3/4″, Knit, Non-roll Elastic: no testing required, always fully encased
  • 1/4″, Knit, Non-roll Elastic: no testing required, always fully encased
  • 1 1/2″, Soft, Waistband Elastic: no testing required due to width and content
  • Coats & Clark Dual Duty XP thread: no testing required due to width and content
  • Stretch Rite Elastic Thread: no testing required due to width and content
  • 100% Satin Tracking Labels: no testing required due to width and content
  • 100% Acramid Tracking Labels: no testing required due to width and content

What information is required on the tracking labels?
All children’s clothing items must have the following on their permanently attached label(s):

  • Who the manufacturer is (usually a business logo)
  • How to contact the manufacturer (usually a website, email address or RN)
  • Where the manufacturer creates the product (City & State)
  • A unique mark or number (batch ID) so you are able to follow recall instructions should the occasion arise
  • When the product was finished (often included in batch ID)
  • How to care for the product.

How can I know if a small business is CPSC/CPSIA compliant?
All you need to do is ask!  Most businesses will have a statement on their website, or listings, that says something along the lines of, “Meets CPSC Regulations” or “Products are made with CPSIA compliant materials.”  They may also have a statement page, like this one.