What is the CPSIA?

No, if your product is still intended for use primarily for children under 12 your product still falls under the CPSIA. In addition, by marketing and selling the clothes as a toy, what once may have only needed lead testing would now need phthalate testing as well.
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While the CPSIA may have been passed as a response to the recall of certain toys that included lead-based paint, the CPSIA was written to include ALL products intended for children under 12. Many people assume it only applies to toys because of the initial media coverage of the 2007 recalls and the subsequent coverage [...]