Well, this is a very complex subject and unfortunately goes far beyond the boundaries of what I can cover in a short blog post, but I am going to do my best to cut through all the legal jargon and describe in laymans terms exactly what this means to our business as an apparel decorator and to you as a consumer, so grab a cup of coffee and settle in because this is truly another mind boggling bill that was enacted by Congress, in their infinite wisdom, and signed into law in August of 2008, and believe me, it can give you a migrain.
In short, CPSIA is an acronym that stands for Consumer product safety improvement act, of which the original intent was to rework the Consumer Product Safety Comission, giving them more authority and improving consumer product safety after high lead content was discovered in childrens toys that originated in China.
The end result however, is straining nats and swallowing camels, and doing irrepairable damage to the screen print industry as well as many other industries that provide childrens products in an economy that can ill afford even more business opression. My comments here will be geared toward the screen print industry since that is what Artistic Apparel LLC does and what we know the best.
Please don’t misunderstand our concern for childrens safety. That is far and away our primary concern, and have done our best as a business to conform despite the heavy burden that has been laid at our feet for no logically apparent reason. In its original form, the CPSIA imposes Lead and Phthalate standards for childrens products being used by those children 12 years of age or younger, and backs up these standards by a mandatory third party testing and certification process. The mandatory third party testing must be done by a CPSC acredited lab. Currently these tests are costing between $50 and $150 for each instance, greatly adding to the cost of Childrens products. To further clarify my point see the etsy’s gallery of unaffordability to see how this is impacting small home crafters.
All of this sounds good on the surface, afterall, we do want to protect our children. The problem is, the bill is drafted in such a way as to require testing of anything that is put on a shirt for lead and sometimes phthalates ( for ages 3 and under ) that is not natural fiber, and this test must be performed on every new batch run and each additional component. ( Four different button styles, four different tests, three different colors of ink, three different tests. ) It is true that the CPSC has now said that component part testing is acceptable, but our ink manufacturer has told us that this is a physical impossibility since they manufacture between 30 and 40 batches a day and with a three to four week lead time for testing, creates a logistical nightmare that they do not have the space or means to confront.
Now, here is the real thing that makes no logical sense, According to our ink manufacturer, there has not been any lead content in their screen printing ink for over 30 years, as a matter of fact, I personally have the test results in my office for the product I use and lead content is 0.00, but this is not acceptable to the CPSC because the lab was not a CPSC acredited lab, and the component parts of the ink were tested and not the final batch.
Why is this a big issue all of a sudden right now? Well, until December 30th of 2011 there has been a stay of enforcement on mandatory third party testing that has now been lifted. The bottom line here is that if you want new soccer shirts for your children 12 years of age of younger, don’t be surprised if you have a very difficult time finding them for any reasonable cost if at all, unless they have no logo’s, names or numbers. And don’t take this lightly, manufacturers that knowingly distribute childrens products without the proper testing and certification are subject to $100,000.00 fines per incidence and maximum of $15,000,000.00 with possible imprisonment of up to 5 years.