CPSIA: Focus On Apparel Decoration

Wednesday, April 18, 2012Mark Bailey, SanMar

Bruce Perryman, MAS, Embroidery UnlimitedAnne Lardner-Stone, PPAI

This information is being furnished by PPAI for educational and informational purposes only. The Association makes no warranties or representations about specific dates, coverage or application. Consult with appropriate legal counsel about the specific application of the law to your business and products.

Apparel Decoration

•Required testing on apparel decoration

•Children’s apparel

•Child-care articles

•Assuring ink compliance

•Tracking labels

•Exemptions

•Case studies

•Best practices

Children’s Apparel Defined

• Infant- and youth-sized garments

Required Third-Party Testing For Children’s Apparel

• If ink becomes part of the garment 100ppm lead limit in substrate

• If ink can be scraped off 90ppm lead limit in paint

• Any hard attachments? both lead limits apply to the decoration

recommended use and abuse testing for

small part detachment

Child-Care Articles Defined

• Garment a child three years of age and younger would use for sleeping, feeding, sucking or teething

– Bibs– Blanket– Sleepwear

Required Third-Party Testing For Child-Care Items

•Lead in paint•Lead in substrate •Lead testing for hard attachments•Recommend use and abuse testing of hard attachments for small part detachment

AND

•Phthalate testing

Children’s products

Child-care

articles

Phthalates Ban

•Ban on six phthalates in child-care articles:

DEHP, DBP, BBP, DINP, DIDP, DnOP

•Third-party testing required

•Inaccessible component parts are exempt

If found, phthalates likely in decoration or

hard attachments such as velcro, vinyl,

zippers, buttons, clasps and rhinestones.

Paperwork Requirements

All testing must be reflected in Children’s Product Certificate (CPC).

• Must be produced and made available for every youth order.

Small Batch Manufacturer Exemption •Applies to manufacturers with a reported income <$1 million for calendar year AND have produced <7,500 units of the product in question

•Must ensure that products comply and issue a general certificate of conformity (GCC).

•For apparel decoration, must still test “scrapable” ink and hard attachments for lead in paint.

•Must register with CPSC as small batch manufacturer.

•Not required to third-party test for:• ASTM Toy Safety Standard• Total lead content in children’s products• Ban on phthalates

•Must test for: • Lead in paint

How can you (distributor or decorator) ensure ink compliance?

Assuring Ink Compliance

•Have all your inks tested

•Rely on ink suppliers’ tests and component testing rule

•Perform third-party tests on finished product

Tracking Labels

•Required for all children’s products manufactured after 08/14/09

•Enhance recall effectiveness

•Required Information:

• Manufacturer name

• Month/year of manufacture

• City/state of manufacture

• Batch or internal order number

• Distributor PO number

When a distributor sources from an apparel distributor, contracts with a third-party decorator to apply ink or thread to a garment, and sells the product, the garment has been altered and…

requires a second tracking label for the same purpose as the first.

Secondary Tracking Label

Required Information:

• Decorator’s name

• Month/year decoration was applied

• City/state where decoration was applied

• Decorator’s batch or internal order

number

• Distributor’s PO number

Secondary Tracking Label

Specifications:

• Must be permanent

• Hangtags and adhesive labels not

acceptable

Secondary Tracking Label Best Practices

Label location:

• Bottom hemline

• Inside back neck

• Sewn in as a label behind the original care/tracking label

Secondary Tracking Label Best Practices

PPAI Tracking Label Solution

• Free to UPIC subscribers

• Allows for short URL to satisfy

requirements

PPAIhttp://ps.ppai.org/SAMPLE01

Case Study 1: Adult-Sized T-Shirt

Required Testing on decoration: •None

Required testing on decoration: •Lead in substrate •Lead in paint

Proof of compliance: •Children’s Product Certificate (CPC) •Test reports from third-party lab

Primary tracking label required.

Secondary tracking label may be required.

Case Study 2: Youth-Sized T-Shirt

Case Study 3: Infant Bib

Required testing:•Lead in substrate •Lead in paint •Phthalates

Proof of compliance: •Children’s Product Certificate (CPC) •Test reports from third-party lab

Primary tracking label required.

Secondary tracking label may be required.

Case Study 4: Infant Sleepwear

Required testing:•Lead in substrate on ink & painted zipper •Lead in paint on ink & painted zipper•Phthalates in “sticky feet,” painted zipper, fasteners and decoration itself.

Proof of compliance: •Children’s Product Certificate (CPC) •Test reports from third-party lab

Primary tracking label required.

Secondary tracking label may be required.

Best Practices

Distributors, ask your buyer:

•Who is the intended audience?• Will this item be distributed to

children?•How will the products be distributed?•What kind of logo do you intend to use?•Do you typically keep items in stock for future use or do you distribute all items?•Do the customer’s preferred products have child-like appeal or playful elements? Or do those products have “diminishing appeal” to the 12 and under crowd?

Best Practices

Distributors, tell your supplier and decorator: •The intended audience

• If the item will be given to children

•The distribution method•The product you want

Best Practices

Maintain records of all compliance documents:

• General Conformity Certificate (GCC)

• Children’s Product Certificate (CPC)

• Third-party test reports

Review PPAI’s How To Read Compliance Documents

Resources

PPAI: www.ppai.org

Product Safety powered by PPAI:

www.ppai.org/productsafety

Consumer Product Safety

Commission (CPSC): www.cpsc.gov

PPAI Promotional Products

TurboTestTM www.ppai.org/turbotest

PPAI Product Safety Summit:

www.ppai.org/summit

Questions? AnneL@ppai.org

Questions?