CPSIA - Consumer Product Safety Improvement Act
What, Why and When?
In 2008, the CPSC enacted a ruling limiting the Lead and Phthalate content in all Childrens’ products. They have defined these products as anything designed or intended primarily for children 12 years of age or younger. It is a response to the massive recalls issued in recent years due to of lead contamination, primarily from overseas toy manufacturers. This, in turn, impacted the garment industry as well. The act has created more stringent guidelines and tracking rules for any garment marketed to those 12 and under. At that time, Lead limits were set to be 100 ppm by 2011 and Phthalates DEHP, DBP, DINP, DIDP, DnOP and BBP were limited to less than .1 %.
In response many ink and embellishment manufacturers took it upon themselves to become compliant with the new regulations. Thus the Phthalate free plastisol inks were born along with child safe rhinestones and water base inks.
What does this all mean to you the garment embellisher? You are considered to be the manufacturer if you embellish the blank good in any way. This means you will be responsible for testing and tracking of said garments.
There are several new regulations and rules to navigate.
- All garments for children under the age of 12 will be required to be tested at an independent accredited lab for lead content. Some products may be exempt or excused from the lead limits if the component containing lead is inaccessible .This refers to any button, zipper, vinyl, ink or rhinestone added to the garment must meet lead ppm restrictions of 100 ppm.
- You will then be required to provide a “General Conformity Certificate” to certify the test was done and the garment is compliant. There are several placed throughout the US. Each item added to the garment would need to be tested. (The garment itself and the dyes within it are exempt from testing).
- All garments for children under the age of 3 will be required to not only test for lead but for Phthalates as well.