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Are you a Small Batch Manufacturer? If So you need to register today with CPSC!

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Jan 2, 2012, by Bill Jacoby

 

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.

 

CPSC Launches Registry for Small Batch Manufacturers

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WASHINGTON, D.C. – Dec 23, 2011, CPSC is launching an easy-to-use registry for small batch manufacturers, which can be found at www.SaferProducts.gov. Congress directed CPSC to establish this registry for small batch manufacturers in Public Law 112-28, which was signed into law by President Obama on August 12, 2011.

Small batch manufacturers, defined as those who earned $1 million or less in total gross revenues from sales of consumer products in 2011, and who produced in total no more than 7,500 units of at least one consumer product in 2011 can register for calendar year 2012 at www.SaferProducts.gov. Qualifying small batch manufacturers are not required to third party test for compliance with certain children’s product safety rules during 2012 for products which they produced no more than 7,500 units of in the previous calendar year.

This new registry does not exempt small batch manufacturers from ensuring that their products comply with these mandatory standards. Small batch manufacturers must still provide a certificate of conformity, in which the manufacturers certify in writing that their products comply with the applicable regulations. However, except where required by law, the certificate does not have to be based on third party testing.

Effective December 31, 2011, the stays of enforcement on third-party testing and certification for limits on total lead content for children’s products, the ban on certain phthalates for children’s toys and child care articles, and the mandatory toy standard (ASTM F963) will end. CPSC launched an education and outreach effort to ensure widespread awareness of the new federal requirements and has also provided assistance and guidance to small batch manufacturers to help them understand these new requirements.

For additional information on the Small Batch Manufacturers Registry and small batch guidance materials, please see www.cpsc.gov/smallbatch. You may also contact our small business ombudsman Neal Cohen at ncohen@cpsc.gov or through www.cpsc.gov/sbo

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The U.S. Consumer Product Safety Commission (CPSC) is charged with protecting the public from unreasonable risks of injury or death associated with the use of the thousands of consumer products under the agency’s jurisdiction. Deaths, injuries, and property damage from consumer product incidents cost the nation more than $900 billion annually. CPSC is committed to protecting consumers and families from products that pose a fire, electrical, chemical, or mechanical hazard. CPSC’s work to ensure the safety of consumer products – such as toys, cribs, power tools, cigarette lighters and household chemicals – contributed to a decline in the rate of deaths and injuries associated with consumer products over the past 30 years.

To report a dangerous product or a product-related injury, go online to: www.saferproducts.gov, call CPSC’s Hotline at (800) 638-2772 or teletypewriter at (800) 638-8270 for the hearing impaired. Consumers can obtain this news release and product safety information at www.cpsc.gov. To join a free e-mail subscription list, please go tohttps://www.cpsc.gov/cpsclist.aspx.

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