FYI – Important if you are a Manufacturer of Children’s Products.
The CPSC has defined a “children’s product” to mean a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, you need to take the following factors into consideration:
- A statement by the manufacturer about the intended use of the product, including a label on the product if such a statement is reasonable.
- Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children 12 years of age or younger.
- Whether a product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger
- The Age Determination Guidelines issued by the CPSC staff in September 2002, and any successor to such guidelines
If you qualify and if you are a manufacturer of children’s products and produce in small batches, it is critical that you register for a small batch exemption if your sales are less than 1 million dollars from the previous calendar year or you have manufactured less than 7,500 qualifying (children’s products) units. Registering for an exemption will exempt you from third party testing requirements under CPSIA. Most apparel products were granted broad exemptions already but this will help you in the event your items include non-exempt components. Another thing to keep in mind is that this is just a testing exemption, you are still required to comply with standards defined under the CPSIA law.
HOW TO REGISTER
This is a two step process. Part one is to register your business which will get you an account user ID if you don’t already have one. It is pretty straightforward.
After you request the business ID, you’ll get an email saying that the CPSC is overwhelmed with applicants but they’ve got you in the queue and will get back to you as soon as they can. This may take up to 12 hours, maybe more. Once they get back to you, you will need to confirm the registration by activating your account by creating a password. You may hit a snag at this point if you’re using the wrong username -say, your company name. The username was created at sign up and consists of your first and last name. Once you’ve activated your account, you can sign up as a small batch manufacturer. This is also fairly straightforward.
As a qualifying small batch manufacturer, you will need to register with the CPSC on an annual basis. You will still need to issue a certificate (CPC/GCC), however you will not need to conduct third -party testing for either lead or phthalate content. Additionally, your products must still meet both the lead and phthalate content limits.
You can visit the CPSC page for more information. Ignorance of the law is no excuse so please register today.