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CPSIA Compliance, Courtesy, Confusion and Compassion

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Down the path to third party testing, confusion about implementation and finally shouting…. This man’s plan of action makes perfect sense to me Top Dealer To Challenge CPSC Lead Content Rule

Background
There’s a law now that bans selling anything that contains lead or phthalates when it will be used by children under 12 (lead) or used as toys or in the care of children under 3 (phthalates). That’s putting it very, very simply and it’s a very, very complicated law. (I won’t even go into the additional requirements for tracking and labeling, that’s a whole different ball of string.) The Government agency mandated with enforcing this law, the Consumer Protection & Safety Agency, has kindly published a guide book for small businesses to use to comply with this law. This Handbook is very helpful in navigating these very very troubled waters.

As you know I make the sewn products for our Montessori materials and furniture company, Hello Wood Products. Since my diagnosis of cancer 2 years ago we’ve let the sewn products line, which is a very tiny part of our production, become a ghost of it’s former self: no advertising, no samples at conferences, no new products. I’ve had orders coming in all along and have filled them but the volume has dropped greatly due to extremely cheap imports and knockoffs. Now the tide of cheap alternatives has been stemmed by the requirement that importers must have General Certificates of Compliance (GCC) on each product, each color, each component.

I must have this GCC as well. So, with a few new orders on the books I have been trying to get my paperwork in order.

My Plan of Action: a “corporate courtesy, middle way, path”
First I called the Vendor from whom I buy a certain brand of zippers. I explained that I needed Certificates of Compliance for Lead and Phthalates because I manufacture for small children. My phone call was transferred to the “manager”. I explained again.

The manager said that their website was experiencing trouble and that she would call me right back. I waited a week.

Then I sent a request through the company’s website requesting the GCCs for lead and phthalates. (I haven’t found a vendor yet who knows what a phthalate is). No response.

So I called again and was told to send the request to the email address on the website and a certificate would be emailed back. No email received.

Meanwhile I found the manufacturer’s contact information on the Etsy CPSIA-Compliance board and used it to contact the US representative of the manufacturer directly, asking for certifications for both lead and phthalates.

I received no response from either the manufacturer nor my vendor after 2 days I sent another email, reminding my dear vendor that the certificates were needed as promised. That same afternoon the manufacturer sent the lead complaince Certificate I already had and the Phthalate Certificate after another request.

And the following is what took place via emails with my vendor, a company with whom I’ve been doing business since 2002. I’ve removed the names of the vendor and the manufacturer.

—————————————————————–

—– Original Message —–
From: (vendor)
To: mary

Subject: Fw: Fw: Urgent CPSIA Compliance (I had explained the lack of response and the fact that I was stalling on filling orders)

Good morning Mary,

Thanks for the email. All (manufacturer’s name) products obey all regulations.

Have a great day and enjoy the weekend.

(vendor’s first name)

Attachments (there were 3)
1. Re: (manufacturer’s name) compliance process regarding CPSIA (H.R 4040) for Children’s products.

Letter dated November 20, 2008, from corporate headquarters located outside United States indicating that the manufacturer complies with the US scheduled deadlines and permitted levels for lead. It also detailed the quality controls in place within this foreign company’s manufacturing systems. Very well done.

2. Copy of the form letter sent out by another small business on her letterhead to all her vendors requesting both lead and phthalate certificates.

I have no idea why this was sent to me but it was dated Jan 13, 2009, but beware: your form letters might be sent around, too

3. Certification of Compliance, Subject: Content of Lead dated Oct 6, 2008 (manufacturer’s name)

General statement with no scientific test results. I am used to reading MSDS (Material Safety Data Sheets sheets and there’s much more information in them than in these Compliance Statements

——————————————————————————–

From: Mary
To: (vendor)
Subject: Re: Fw: Urgent CPSIA Compliance

Thanks (vendor’s first name):

I am really concerned about the phthalates content of the plastic molded zippers but these certificates do not address that issue. Please advise.

Mary

——————————————————————-

—– Original Message —–
From: (vendor)
To: Mary
Subject: Re: Fw: Urgent CPSIA Compliance

(manufacturer’s name) OBEYS EVERY LAW! You do not have to worry. We sell to alot of children clothes companies. Just do not buy imported zippers.

——————————————————

Necessary comment to you, dear reader: what I buy through my vendor IS imported

——————————————————

—– Original Message —–
From: Mary
To: Vendor
Subject: Re: Fw: Urgent CPSIA Compliance

I received this just now from (manufacturer’s name). You probably will like to have it on file as well.

Thanks for all you do
Mary

my attachment of manufacturer’s phthalate compliance

———————-

From: Vendor
To: Mary
Subject: Re: Fw: Urgent CPSIA Compliance

THANKS

I HAVE ALL THE COMPLIANCES ON FILE…..(manufacturer’s name) OBEYS ALL LAWS.

(signed: Vender’s first name IN ALL CAPS)

—————————————————————————————

Sooooo, why didn’t it get forwarded to me in the first place, weeks ago????????? Grrrrr

This was for lead and phthalates content of only one component in our product line and the vendor who seemed the most accessible. Testing for phthalates is expensive and I would have to sell as many of this item as I have sold from 2002 to date to cover the cost of testing one batch. And that means that there would have been absolutely no profit made in all those 7 years. But I must test if I suspect that phthalates are in this product and that a child under 3 might use this product as a “toy”. Give me that crystal ball! I sell to schools for use of children over 3!

I feel like what our 14th Dalai Llama said this past week, “The Middle Way has been a failure!” could easily be applied to my version of the middle way, Adjust and Cope, Adjust and Cope.

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About Mary Beth

I am fascinated by changing patterns and colored threads. I sew garments and am teaching myself to machine knit. Since selling the building that housed my workrooms, The Stitchery, I'm searching for a place to set up the knitting machines again. There must be room here somewhere!

4 responses »

  1. How incredibly frustrating!!

    Reply
  2. Pingback: Pages tagged "helpful"

  3. Wow. More words just fail me. Wow.

    Reply
  4. Pingback: Unbelievable! US Treasury in the Dark…Reeeeallly? « The Stitchery

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