Apparel/Textile

Danielle Elizabeth Designs tweeted a link to a picture of her tracking/care label.  Apparel is already required under other laws to have labels.  CPSIA tracking information can be added to existing labels; the tracking label does not have to be a separate label.

Barking Dog Designs has a two-label solution; one with the business name, the other with the care instructions and other info.  Pictures here and here.  Remember, the information on tracking labels does not all have to be physically in the same spot.  Barking Dog Designs also uses an RN number, which enables customers to look up the business name and location in the FTC’s database.

Challenge And Fun reports that one of their vendors uses small, ready-made size labels to indicate their batch numbers on fabric dolls.

Sue of Ecoleeko has a unique method.  She uses an inexpensive set of rubber stamps to ink her tracking info onto fabric tape, then heat-sets the ink.  If you’ve been considering hand-writing info on your tags, you should look at her idea; the results are very professional looking.

Yarn crafts (crochet, knit)

Curious Workmanship glues tracking labels printed on a laserjet to her hand-crocheted baby booties.  Description here; picture here.

Hair Bows

InfantBows is not using tracking labels, since small unlabelable items are not required to have labels.

Toys

Greco Woodcrafting has their tracking label info laser-etched onto their wooden toys, and recommends collaborating with local businesses if you can’t do an in-house labeling solution.

A business that wishes to remain anonymous stamps their info onto wooden toys using permanent inks.

Books and paper goods

Lunasea Studios incorporated their tracking info into the copyright page of their Little Vampires books.

Hilary of Blynken and Nod has to hand-write her info onto her scavenger hunt card sets, but makes it look more professional by also signing and numbering each set.

Companies that make labels in small quantity, that have been recommended by small businesses:

Namemaker

Custom Couture Label Company

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• toys for children of any age must not have any of the 3 prohibited phthalates
• toys that can be placed in a child’s mouth must not have any of the 3 prohibited phthalates or violative concentrations of the 3 restricted phthalates
• feeding and child care items for children under 3 (we await a formal definition of which items fall in this category)

The following materials are exempt from third party testing for phthalates, as per CPSC’s policy statement:

• unfinished metal
• ordinary fabrics and yarns made from natural and synthetic fibers like polyester, nylon, acrylic, cotton, wool, etc.
• polyethylene, polypropylene, and polyolefin
• silicone rubber
• natural latex
• mineral products such as play sand, glass, and crystal

However, if any of these items have on them a coating that might contain phthalates, such as a screen print on a cotton tee or a waterproof coating on fabric, the coating is not exempt from phthalates testing.

Here is a partial list of items that MAY NEED phthalate testing:

• Elastic
• PUL (polyurethane laminate fabric, used in cloth diapers)
• Fabric finishes
• PVC and vinyl
• Adhesives
• Electrical insulation
• Foam rubber
• Surface coatings and decals

Source your materials with care if you use any of these.

Some important things to note about this policy:

• These exemptions are for phthalate testing ONLY.  A material may be exempt from phthalate testing but still need to be tested for lead for CPSIA compliance.
• Phthalate testing is on a component basis.  So if you use cotton flannel and PUL to make a diaper, only the PUL needs to be tested for phthalates, NOT a finished diaper.  An “I Spy” bag with a vinyl window would need the vinyl tested but not the thread, fabric, etc.
• The policy statement linked above does not specify whether inaccessible component parts will need to be tested for phthalates.

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It is important to remember that the CPSIA includes ALL products made for children under 12 which means that any article of clothing, backpacks, bicycles, children’s motorbikes, blankets, bibs, wooden toys, etc. all fall under the letter of the law.

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Even if followed in good faith, violative products will still end up on the market because CPSIA uses a technique called “sampling.”  “Sampling” means that only a sample of the products are tested.  If 1 in 100,000 snaps have too high a lead level, and only 5 snaps are tested, the 1 that is too high may not be among the 5 that are tested therefore the only way to make sure everything does not violate CPSIA’s standards is to test everything.  The tests for lead destroy the items, however, which would mean that no children’s products would ever make it to market.

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“Anything” includes more than just toys.  It means books, clothes, bicycles, pens, school supplies, science kits, exercise equipment, off-road vehicles, shoes, socks, maps, bath toys, and musical instruments.  Anything that you buy for a child, that is given to a child, or that a child uses in school is subject to CPSIA.

Items like car safety seats, foods, cosmetics, and some soaps are not covered under CPSIA because they are regulated by another government agency.

CPSIA also applies to goods that are “distributed in commerce.”  Commerce doesn’t mean only buying and selling.  Under the law, “commerce” also includes things that are given away and even includes lending libraries.

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First, the recalls were voluntary.  That means that as soon as the company found out there was lead in the paint, they recalled the toys.  The government did not have to force them to do it, but helped them do the recall by putting out a notice.

Second, the amounts of lead paint in many of the recalls were so tiny that the child would have to actually eat hundreds or thousands of the same toy all at once in order to absorb enough lead.  No child could do that!  So in many of these recalls, no child was actually in any danger.  The recall was done because the paint violated existing pre-CPSIA law.

Third, some people think that if a toy is recalled, it must have harmed someone.  This is not true.  Most recalls are done before anyone is harmed, and in many cases the recall is done not because of danger, but because of a technical violation of a safety law.  More complicated laws increase the chance that somebody will forget a piece of paperwork somewhere or that something will slip through the cracks.

Finally, CPSIA would not have prevented these recalls.  CPSIA requires that children’s products be proven lead-free before going to market by testing a sample.  These toy companies did test samples and a mistake was made.  Laws do not prevent people from making mistakes.  The recall system is here to help when mistakes are made, and it worked in 2007.

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