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Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

 
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Old March 15th, 2012 Mar 15, 2012 4:21:09 AM -   #661 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Put it on your General Conformity Certificate that you are going to provide to your customer. The tracking label needs to have your company name, contact info and some type of identification # that can link back to where it was made / when it was made / how it was made / products used to print the garment.

Keep an eye out for the April edition of Printwear magazine as there is going to be some articles on CPSIA.

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Old March 15th, 2012 Mar 15, 2012 7:07:40 AM -   #662 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Your small batch registration number goes on your compliance form. Your tracking label only needs to have: 1. Your contact info (this can be a phone number, web address, or complete physical address). 2. Some type of batch number or other order identifier (this can be the invoice number for that particular order), 3. the date of printing.
 
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Old March 15th, 2012 Mar 15, 2012 8:32:14 AM -   #663 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

What about personalized water bottles, bag tags and towels that are for kids?
 
 
Old March 15th, 2012 Mar 15, 2012 8:52:41 AM -   #664 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Unfortunately, this requirement is NOT limited to wearables. ANY item that would have it's PRIMARY or INTENDED use by kids 12 & under fall under this requirement. There are lots of gray areas such as the water bottle. If sold as a general water bottle for all ages use, then NO....but if personalized with a kids name, or lets say printed for a kids summer camp, then YES. It's all about the Primary and/or Intended use by a specific age group. An adult small t/shirt would not be required, since it's marketed as an ADULT size shirt, even though lots of kids wear adult size shirts. Once again, lots of gray areas, and this law is very complex, so each item has to be judged on it's own intended use.
 
Old March 16th, 2012 Mar 16, 2012 6:17:31 AM -   #665 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

I was at Walmart the other day and out of curiousity I looked at kids' clothing that was decorated. I searched all of the labels and inside printing and could find nothing that would match what has been said that we as small business need to put on garments. No special labels. No compliance / tracking info.

If Walmart suppliers aren't doing this, why do we have to?
 
Old March 16th, 2012 Mar 16, 2012 7:03:09 AM -   #666 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Could be old stock that was printed before end of last year, but it should have the tracking label at least. Didn't say this new law was fair, especially to the small printers. It's possible that Wal Mart & other big retailers have some phase in period for their inventory, since sometimes that inventory that's currently on the rack was printed up to a year ago, and now it's finally hitting the retail market. The final version of the CPSC law "officially" kicked in Jan 1 2012, so anything PRINTED prior would have some exemption status.
 
Old March 16th, 2012 Mar 16, 2012 7:38:39 AM -   #667 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Quote:
Originally Posted by fdsales
Could be old stock that was printed before end of last year, but it should have the tracking label at least. Didn't say this new law was fair, especially to the small printers. It's possible that Wal Mart & other big retailers have some phase in period for their inventory, since sometimes that inventory that's currently on the rack was printed up to a year ago, and now it's finally hitting the retail market. The final version of the CPSC law "officially" kicked in Jan 1 2012, so anything PRINTED prior would have some exemption status.
This has been law for 2 years, only the testing was delayed.
I hope they turn their inventory quicker.
 
Old March 16th, 2012 Mar 16, 2012 8:34:58 AM -   #668 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Yes, you are CORRECT. That's way I stated there should have been, at the very least, a tracking label on the garment. Once again, big retailer, so maybe Wal Mart has some "pull" with the CPSC to obtain some type of waiver of time. I guess best answer would be to contact the local CPSC office for that area, and ask the same question of them.
 
Old March 16th, 2012 Mar 16, 2012 12:22:00 PM -   #669 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Quote:
Originally Posted by fdsales
Yes, you are CORRECT. That's way I stated there should have been, at the very least, a tracking label on the garment. Once again, big retailer, so maybe Wal Mart has some "pull" with the CPSC to obtain some type of waiver of time. I guess best answer would be to contact the local CPSC office for that area, and ask the same question of them.
I think the problem is that they past a vague law and noway
to really enforce it.
 
Old March 17th, 2012 Mar 17, 2012 6:53:03 AM -   #670 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Quote:
Originally Posted by irish
I was at Walmart the other day and out of curiousity I looked at kids' clothing that was decorated. I searched all of the labels and inside printing and could find nothing that would match what has been said that we as small business need to put on garments. No special labels. No compliance / tracking info.
Tracking labels remain a matter of confusion. The simplest way to answer this question is to say that Wal-Mart (et al) have always had tracking labels. The only change there may be in their tracking process is documentation with respect to cpsia testing that they keep on file.

The issue at heart is tracking period, not cpsia tracking per se. More professional enterprises have been tracking output by lot number for a very very long time and that is the essence of what cpsia requires. In a manner of speaking, requiring tracking is a way that CPSC has put small producers on notice that they must adopt standard industry practices that larger firms have used for years.

If you're looking for a standard stand alone label, you shouldn't be surprised if you don't find it. However, the required information is there, it always has been. Some of the compliance is provided by following the Federal labeling law itself (country of origin, origin of fabric, content, RN etc) which long preceded CPSIA and that many small companies ignore or think doesn't apply to them because they're small. The remainder of cpsia tracking by large firms is done with a lot number. Again, more professional firms have always done this if only as a way of tracking product quality and in the event of liability claims (say a pin is left in a garment, the company wants to know which contractor produced it and when). The intent of the law is that a consumer should be able to supply a lot number and the chain of production and supply can be determined. Smaller companies typically don't follow the federal labeling law (precedes CPSIA by decades) much less do they track production by lot.

Here is more info: Fashion Incubator » Blog Archive » CPSIA: Another tracking label update

What it boils down to is that smaller producers are being required to up their game with respect to managing their production. Personally, I think this is a good thing because too few producers do it. Either they think it is overkill or they don't know how to do it but being able to track all this stuff is a direct process that makes you more profitable.

When small producers talk about moving up to another level, they usually refer to getting more for what they're already doing, namely more sales, prestige etc -but that isn't enough. What you've done so far just gets you in the door but it doesn't get you a seat at the head table. To do that, you have to up your game. If you want to move up to another level, you have to move your practices up another level too.

Truly, the only part of the tracking label requirement that should be challenging for smaller firms is the matter of having to print/create a small quantity of labels with a unique lot number because their lots are so much smaller. There are ways to deal with this too but it is pretty much a moot point because small producers aren't managing product lots in the first place. Many don't even understand what a lot or batch is.

In summary, the tracking label requirement speaks to operational compentencies. Professional means better, not bigger.
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Old March 20th, 2012 Mar 20, 2012 11:33:14 AM -   #671 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Well I guess this is one way to deal with it. Found this on the indise of a Mmajor sports brand. Interestingly, it is on a youth sized tee.. hmmm...

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Old March 20th, 2012 Mar 20, 2012 11:49:23 AM -   #672 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Interesting concept. Not sure how the CPSC would look at this since it was done on a youth garment that was most likely marketed to children 12 years and under. In my opinion, this would be like putting a label on cigarettes that they should not be smoked by people under 18 years old... but allow anyone to buy them. Again just my opinion..., but I would not be comfortable doing this.

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Old March 20th, 2012 Mar 20, 2012 11:50:39 AM -   #673 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

What size youth tee? If youth large or youth XL, they may be able to get away with it, but still very ingenious.
 
Old April 12th, 2012 Apr 12, 2012 1:50:08 PM -   #674 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Quote:
If you're looking for a standard stand alone label, you shouldn't be surprised if you don't find it. However, the required information is there, it always has been.
I did not expect a standalone label, but maybe some off-the-wall number on an existing label. Nothing. I went to Target and same thing. This was in a major metro area, so stock turn-over would be much more than in the small Walmart at the farm, where we used to go.

Quote:
Truly, the only part of the tracking label requirement that should be challenging for smaller firms is the matter of having to print/create a small quantity of labels with a unique lot number because their lots are so much smaller.
How about a lot size with a quantity of ONE??? It is a royal PIA to make labels for every single garment.
 
Old April 12th, 2012 Apr 12, 2012 2:01:44 PM -   #675 (permalink)
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Default Re: Confused by new CPSIA laws? I am! Do you sell anything to kids ages 12 and under?

Quote:
Originally Posted by irish
How about a lot size with a quantity of ONE??? It is a royal PIA to make labels for every single garment.
Not if you digitally print the label on the garment. Remember, the term label does not have to be a traditional woven tag. I am of course assuming you do some type of digital printing since you are stating a single garment. Only other way would be a plastisol transfer since the garment would not be finalized till the day you press it.

I really don't see the tracking label being the challenging part to this law. The coordination of the documents is what I would like to see a business management software program incorporate into it.

Just my opinion,

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