CPSIA: Focus On Apparel Decoration

CPSIA: Focus On Apparel
Wednesday, April 18, 2012
Mark Bailey, SanMar
Bruce Perryman, MAS, Embroidery Unlimited
Anne 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
•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
•Phthalate testing
Phthalates Ban
•Ban on six phthalates in child-care articles:
•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.
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
•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
•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.
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
•Distributor’s PO number
Secondary Tracking Label
•Must be permanent
•Hangtags and adhesive labels not
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
Case Study 1: Adult-Sized T-Shirt
Required Testing on decoration:
Case Study 2: Youth-Sized T-Shirt
Required testing on decoration:
•Lead in substrate
•Lead in paint
Proof of compliance:
•Children’s Product Certificate
•Test reports from third-party lab
Primary tracking label required.
Secondary tracking label may
be required.
Case Study 3: Infant Bib
Required testing:
•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
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
Best Practices
Distributors, ask your buyer:
•Who is the intended audience?
•Will this item be distributed to
•How will the products be
•What kind of logo do you intend to
•Do you typically keep items in stock
for future use or do you distribute all
•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
•The intended audience
•If the item will be given to
•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
PPAI: www.ppai.org
Product Safety powered by PPAI:
Consumer Product Safety
Commission (CPSC): www.cpsc.gov
PPAI Promotional Products
TurboTestTM www.ppai.org/turbotest
PPAI Product Safety Summit:
Questions? [email protected]

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