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By Kathleen Fasanella on Dec 3, 2008 at 5:54 pm
Admin note: My site host says this site could go down for 30 minutes between Wednesday, December 3 2008 @ 10:00 PM through Thursday, December 4 2008 @ 2:00 AM PST.
The title of this entry is a good summary of the AAFA meeting. Not to say people didn’t have a handle on the situation, just that you’re not the only one who is perplexed by the CPSIA regulations and proposed implementation. I don’t even know where to start so this I guess this is a sort of debriefing dump.
To give you an idea, I heard a lot of the same questions there that I’ve heard from many of you. For example, one person thought they were off the hook for the new CPSIA regulations because they only do full package private label and thought their package supplier was going to have to deal with this, not them. Okay people, let’s do a quick review of Manufacturing 101 because many here are also confused on the matter. Whether you own a single sewing machine, you are the manufacturer if you cause the item to exist. That is a legal designation and not my opinion. As an example, go argue about it with the state of California. They are never charmed or patient with one’s self determined definitions of “manufacturer”.
Another item of contention was -get this- what is a style number? And you thought it was just me who ragged on you about those. Debate centered on what is a style number because even there, not everyone uses or designs them to mean the same thing as I’ve explained here. The reason it matters is because required testing will not be according to the looser definition of style number but most likely according to SKU which could be crudely described as the “child” of style numbers. So the end result is, if you’re not on the same page as everyone else and using accepted garment industry practices, something as silly as lack of style numbers (industry standard practices) will trip you up if you’re not following them. The discussion of style numbers, SKUs and tracking processes were just a few things that led me to believe that you won’t be able to skate by on your homegrown developed organizational processes -if you ever really could. Nope, you’re going to have to be a lot more professional. A logical consequence of this legislation is that kids wear manufacturers will become the barre or minimal standard in the application of garment industry standard practices. Better get that book I wrote if you don’t have it yet. If you have it, go to page 205 (The Big Dirty Secret) which will vis a vis, tell you a lot. You’d think I’d be used to it by now but it always side swipes me.
Another thing, you’re not the only one feeling beat up about this. A lot of people are in the same boat. I think manufacturers are missing a tremendous opportunity. Consumers stand to lose a great deal; it’s a matter of explaining what those losses represent before we can hope to elicit their support. I believe this because about 20% of the visitors to this site are consumers rather than manufacturers. As far as I can tell, they are just as upset as we are. When I’ve explained what this means to them and us, they totally get it. I’ve composed a list of eight central reasons they appear to be opposed to the legislation too. They’re writing letters to their legislators and talking about it on their blogs to educate other consumers. Consumers are our friends, not just our customers.
This is how I reduced it down. If manufacturers are confused about the law and retailers are confused about it too, then why does the implication exist that the only group who does understand the legislation are special interest groups? I say this over and over till I’m blue in the face but never attribute to malice, that which can be explained by stupidity -not to imply they are stupid, it’s an expression. Based on conversations with the groups I’ve spoken with, at least one on one, they can minimally be described as dismayed at the unintended impact of this legislation. I believe it is incumbent upon us to educate and partner with them to explain the far reaching consequences before it is too late.
All in all, it was a good day. I met some people who are really great, very knowledgeable and friendly. I look forward to telling you more later. I’m tired. Hope your day was a good one.
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By Kathleen Fasanella on Dec 2, 2008 at 3:40 am
Cape and tights packed (don’t want them mussed), I’m off to Washington DC today to do my part in making the world a safer place for clothing designers, slaying that CPSIA dragon (pardon the mixed metaphor). Yep, I am. Yeah me. Last week I mentioned I was going, don’t know if you remember. I have to leave here at four in the morning to get to the airport (an hour’s drive away), then I’m on a plane all day. I arrive Dulles at 3:55 EST (two stops, change planes once). In my fantasies, I’ll get off the plane and be whisked away with curbside service (by my adoring fans) to my hotel in Georgetown followed by a fine dining experience (they’re buying). In real life, it’ll be Super Shuttle and that Einstein’s bagel place over there by Tulane. So, long story short, if you need assistance of any kind, I will have a great excuse for failing to respond in a timely manner today other than poor time management or bad time management. Or even, questionable time management like it usually is.
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By Kathleen Fasanella on Dec 1, 2008 at 4:08 pm
Let me preface this entry by saying that no one I’m working with should feel this is directed at them. It’s not. Really. This is an ongoing source of confusion that seems to be rampant lately in other forums and those of you who have participated in those other communities know exactly what I’m talking about.
So let’s get to the heart of it, what is CAD?
- CAD is Computer Aided Design
- CAD is Computer Aided Drafting
At least in our industry, these are not the same thing and while I can’t say they are never interchangeable because I can’t know all import specs on every CAD drafting program, let’s just say they rarely are. The problem is that many people think CAD design and CAD drafting are interchangeable and this gives rise to a whole host of communication problems and excessive costs that could have been avoided. Even Mr. Fashion-Incubator (an electrical engineer) complains about Illustrator files he gets that are claimed to be drafted blueprints.
- CAD Design is done with programs like Illustrator. There’s some other ones too.
- CAD Drafting is done with programs like Gerber, Lectra and Optitex.
Now, I will not deny that there are people who can draft in Illustrator, I’m sure there are. The issue is, how useful is it? Does this represent the best expenditure of your dollars? I would say probably not. The reason is your pattern -in effect, an illustration- can’t be exported into a computer aided drafting program for the purposes of grading and making markers. So like it or not, you will have to have the work redone in a drafting program.
Here’s two examples of what I mean of an illustrated pattern from someone who used Illustrator.
Okay, I realize some of you are falling over yourselves laughing but you would not believe how many “patterns” I have gotten that are just like this. The client assures me over and over that the pattern is ready to go and just needs to be made into a marker. The person who hired the job out considers them to be patterns (I’m guessing) because the illustration is full scale and according to specified dimensions that are usually labeled neatly off to one side. That’s really nice and it’s not that these aren’t useful, but these are technical illustrations, not blueprints. I don’t know of a miracle worker on the planet who can pull in one of these “patterns” and make a marker from it. Besides, if your CAD designer is using Illustrator to draft, that should raise several red flags right there. First it is very likely they are not specialized in the apparel industry because they’d know our marker making software won’t talk to these files so they wouldn’t be using Illustrator to begin with. If they don’t know enough to know Illustrator won’t work, how will they know the seam allowances or construction? Is your designer/drafter an expert seamstress? As I’ve said ad nauseum, patterns are tools. How can one design tools unless they know how to use them?
There was one really infuriating example with this guy who wanted his patterns graded in Illustrator because that’s the program he uses to render the artwork designs (tee shirts of course). Nothing we said held any sway. You can’t grade in Illustrator. The only way you can grad in Illustrator is to give it an “F”. Regardless of whether he’s found someone to do it, there is no doubt he’ll need to hire someone else with a CAD drafting program to do it all over again. And sure, you’re the boss but boss or not, it doesn’t mean we can work in your preferred software program. Unfortunately, you’ll have to bend on this one.
From a production standpoint, below is the most basic rendering of what a pattern looks like.
I’ve gotten patterns similar to this too. But again, because the designer is not an authority in the apparel industry, they don’t know this is nowhere near what we need. I realize this may sound trivial and nit picky but we need to know several things such as fabrication, piece names, size and how many of each piece to cut. As such, we’re more accustomed to something like this below.
Now this still isn’t enough, sad but true. Your illustrator may have spec’ed out your product to scale but they didn’t know about all the internals that go into making the product; this is a function of computer aided drafting, not design. A complete pattern will look more like this (below).
This still isn’t enough to make a marker from. Minimally, you will also need a direction card, aka face card, aka pattern card (page 79 of my book). Making this is the responsibility of whoever makes the pattern. Actually for a marker you really need a cutter’s must but anyone could get the needed information off of a properly made pattern card. To have a marker made, you will also need to design a cut order plan. This can be found on pages 116-118 of my book (see “marker planning”) but more broadly, that whole section spanning pgs 114-120 is pertinent. It seems many designers skip that section being production related and technical but really, you can absorb enough of the material to get the desired result from a service provider.
What many also don’t realize is that they need more than one marker made. The example I’ve shown here actually needs three. One for shell,
another for lining (left) and another for interfacing (right)
because these are the material groupings of all the inputs that go into it. The problem with many of the (pretty) Illustrator files I’ve seen are that pattern pieces representing different materials are laid on top of one another (like a technical sketch) rather than separating them out by pieces.
In the end, illustrators are great at making pretty and tidy illustrations, but these do not patterns make. Better to know that now than to find out with your back up against a wall with a production deadline.
Now, if it is true that your illustrator has spec’ed the design out properly to scale, your best option is to have it printed out and sent off for digitizing. Contrary to prices I’ve seen around, this isn’t an expensive job. I don’t know what other people charge but my son does it for me part time and I bill it out at a rate of $25 an hour. A design like this, such that I’ve shown here with 20 pieces would take an hour and a half at most. I would think the highest hourly rate you could expect to pay would be $50-$75 an hour. This is because some pattern makers don’t have an assistant or intern and have to charge their regular pattern making rate.
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By Kathleen Fasanella on Nov 26, 2008 at 4:21 pm
Previous entries are here, here, here and here. These links will be repeated at close.
In this portion I’ll explain which classes of products need to be tested, if they need to be tested and how this is effected. This first part will deal with kid’s products. Even if you don’t make kids products per se, please humor me and read it because some obscure things can affect you and you don’t want any nasty surprises.
Children’s wear:
Not everything is tested equally under this new law so pay close attention. If you are currently making a product that falls under other CPSC guidelines such as for flammability, you can continue to use component testing for those attributes. You are also permitted to use vendor supplied third party certifications for product integrity. However, the lead and phthalate aspects are different. For lead and phthalate, unit testing is required; this is separate and apart from flammability and draw cords and what not.
What must be tested: Lead
All sewn products intended for use of children 12 and younger must be unit tested for lead at this time. Lobbying groups are looking for exclusions for certain categories of goods like tee shirts. Toward the end of proving lead is not a dangerous element in kid’s apparel, I have been asked to make a request of you. If you have any lead or phthalate test results from a certified laboratory, please send them to me and I’ll pass them along.
Another question I’ve been asked is, “can I use my supplier’s third party certifications to comply with the lead and phthalate law instead of testing it myself”. The answer is no. You cannot. I mean, not for lead and phthalates but you can for flammability etc.
A note to adult clothing producers:
Sure, you read 12 and under and breathe a sigh of relief thinking this doesn’t apply to you but don’t be so quick. From now on, I will be recommending that everyone place a line of copy on their hang tags and on their order form that reads “This product is not intended for use by children aged 12 and under.” The reason is, you really have no assurances that it won’t be. Maybe a twelve year old is mature and likes your stuff or mom buys it and gives it to her. If you don’t actively market your product as intended for adults, you may have to test your products too. Two of the panel speakers (Rachel Murray Meyer and Carol Pollack Nelson) provided some provocative ideas about age grading, human factor assessments and targeted age related marketing that could trip you up. For example, considering how popular the application of Swarovski crystals on tee shirts has become, particularly with tweens… well, I think that’s enough said. If you didn’t know, the crystals are almost entirely lead.
What must be tested: Phthalates
Since we’re just doing sewn products, I’ll restrict my comments to that. Phthalates are a plasticizing agent. It can (potentially) be found in several child related products. Not all children’s items must be tested, only certain categories and then, only products intended for children aged 3 and younger (caveat on the age disclaimer above applies). Specifically, sewn products that are described as “child care” items must be tested. These include items such as bibs, diapers or diaper covers, footed pajamas etc. In other words, such items that contain plastics or plastic coated materials.
That’s all for now; I have every confidence you’ll let me know if I missed anything.
Related Entries:
New product safety regulations that affect all manufacturers
CPSIA Requirements
National Bankruptcy Day
CPSIA: Unit vs Component Testing
Related in the forum:
CPSIA & Consumer Safety. This is a very active section with 17 different threads.
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By Kathleen Fasanella on Nov 26, 2008 at 3:16 pm
Previous entries are here, here and here. These links will be repeated at close.
I don’t know how you’re feeling about this but I feel very discouraged much of the time. No, I don’t make children’s clothes but a great many of my friends do. Even if you don’t either, I’m hoping you’ll follow this closely and lend your support just as if it affected you directly. They don’t have any friends other than us.
At this point I’ll try to clear up a few questions that have been posed and provide other resources. I’m using four main sources for these entries.
- The AAFA -which I joined (@$3,000 fee!)- they’re having a Product Safety Council Meeting on December 3rd in Washington D.C. which I will be attending for up to the minute information and strategy. I hope you guys appreciate this; other than the costs I’m not fond of travel. I don’t have anything to wear either. I’ll be so outclassed it’s not even funny. Most of their members earn more in annual salaries than my gross annual sales so you could rightly surmise a bit of trepidation on my part.
- The CPSC website. There’s a listserv you can be added to upon request which will send you the rulings as they are released. If you need to catch up, here are all of the General Counsel advisory opinions released so far (scroll down).
- The videos of the CPSC Public Meeting on lead. There are three of them: staff and panel presentations and a Q & A. Of these, I’ve found the panel presentations from PLU to be the most interesting. As I write this entry, I’ll be referring to specific speakers in the panel discussion. It’s worth a listen with the exception of one guy I’ve dubbed Captain America for posturing and adding little to the content. This being a public blog I can’t say who that is but anyone who was there or watches it will know exactly who I’m talking about.
- The videos of Rick Woldenberg’s portion of the panel presentation. His presentation was so good, somebody took it upon themselves to post it on Youtube in three parts. He’s not a professional speaker and it takes him a few minutes to hit his stride but he is nothing short of compelling and convincing. While a large concern (a manufacturer and distributor of toys), he cogently makes the case of why these laws would adversely affect small producers too. If you only follow one link from this entry, this is the one to watch.
The rest of this entry focuses on unit vs component testing, what it means and why it matters.
Unit vs Component Testing
Component testing means you can test your inputs (fabric, buttons etc) going into the product individually. Unit testing means a completed product is tested rather than individual inputs. In the panel discussion, Stephen Lamar (AAFA) talks about this, some 21 minutes into the video. He also mentions this law is overwhelming the testing community because we don’t have enough labs even assuming everyone had the time, money and logistical infrastructure to do it.
Component testing is preferable for two main reasons.
- This saves money and time if you’re repeating fabrications and inputs over several styles -as you should be for continuity purposes and meeting minimums for purchasing.
- It achieves the safety intent of the law best.
Unit testing is not preferable for two reasons:
- It’s wasteful. If you’re using the same exact inputs in your products across styles, it’s dumb to retest the same zipper that is identical in each unit.
- It is less safe, circumventing the intent of the law. Let’s say you melt down a widget or whatever to reduce it into constituencies for testing. The total weight of the product is calculated in comparison to the weight of lead or phthalates so maybe the product is deemed within guidelines -but that doesn’t mean it’s safe. For example, let’s assume the major attributes of the product -like a flat screen tv- are inaccessible to a child and won’t be touched by them but the on and off button is and it’s completely constructed of lead. Should this product pass? Under current guidelines of unit testing it would but it shouldn’t. It would not pass with component testing. In other words, it is more important to test inputs as those can be weighted with respect to accessibility by the child.
Perhaps you’re asking yourself why lead needs to be in anything at all. That was addressed best by Christopher Cleet from the Information Technology Industry Council in the panel discussion (he was a good speaker). He said (paraphrased) “it’s not that we have truck loads of lead and are looking for a place to put it, it’s that it’s needed and useful”. Take your typical TV; that screen glass is full of lead (so don’t let your kids lick it). It has to be, otherwise viewers would be exposed to radiation. Mr. Fashion-Incubator concurs saying lead solder is best. In the EU, they’ve gravitated to tin solder (RoHS). The problem with tin solder is that it’s a friendly and sociable metal and likes to hook up with tin solder nearby forming tin whiskers. This will short out the unit causing failures in everything from pacemakers to video games. He adds that this will happen after your warranty is expired leaving you stuck with a lousy product.
At the risk of being pilloried in the community, it’s only fair to mention two reasons why unit testing is preferable. I didn’t hear any of the speakers mention these and it’s important to address so we can develop appropriate resolutions.
Why unit testing is preferable:
- The veracity of component testing can be questionable under certain circumstances. By this I mean that it is very very common in outsourcing situations for your contractor to make unauthorized substitutions for components at the last minute. This is the bane of small manufacturing. While you may have tested the proposed component when in the sourcing stage, unless you’re a large concern who operates your own plants overseas, you often don’t know what you’re getting until it lands at the dock. At this point you don’t have many choices. Maybe you’re “lucky” in that the only last minute change was shortening the sleeves but you’re stuck. You have to get with buyers to see if they’ll take the goods, hopefully without a discount or other losses.
- The other problem with component testing is that just as we make prototypes which we then present to buyers for orders, our suppliers do too. Just as you sometimes have to make changes to a style that was ordered and have to go back to your customer and okay the change, we’re working off of prototype components sometimes. You only have assurances on stock items. This is why suppliers will often call you to glean the liklihood of you buying a particular item down the road because they want to know if they’ll have enough orders themselves to justify producing it. As with us, there may be changes between the prototype and production component.
This is probably enough for one entry. I’ll continue in part two.
Related Entries:
New product safety regulations that affect all manufacturers
CPSIA Requirements
National Bankruptcy Day
Related in the forum:
CPSIA & Consumer Safety. This is a very active section with 17 different threads.
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By Kathleen Fasanella on Nov 25, 2008 at 4:00 pm
There are a variety of ways to express the philosophical values inherent in your company to consumers. These strategies range from patently obvious to pathetic to the parasitic. I call this the three P’s of authenticity. While the patently obvious -better known as cause marketing- can be dicey if not well done, you want to avoid pathetic and parasitic at all costs. Unfortunately, it seems that many designer wannabes tend to favor the latter two. First a run down.
Patently Obvious: Cause Marketing
While I’m not a fan of cause marketing personally, I think it is the most authentic of the 3Ps. Cause marketing means you donate x dollars to a given charity as a percentage of sales or for returning a yogurt lid or something. This can be very effective as repeated studies show a high percentage of consumers favor brands who use these strategies. Efficacy of dollars donated is another thing and the cause for sometimes cantankerous debate. The reason I feel this cause marketing is most authentic is because, as one manager said, “When you’re spending from your marketing budget and not your philanthropy budget, you have to look for that return on investment.” At least they’re honest about it.
Probably the best contrary opinion on cause marketing in these parts was posted by Alison.
I want my charity dollars to go to organisations that fund action. Since businesses typically fund vague, broad-reaching campaigns that touch everyone similarly, these tend to be more like awareness campaigns than like, say, a scholarship program for an orphanage in India. Increasing your margins so that you can fund an organisation that I do not care about (or that I care about and already fund) then you are reducing the viability of your business by increasing your prices and therefore reducing value. By marketing themselves with something peripheral or completely irrelevant to the business, the business is telling me that they don’t trust me to buy their product based on the merits of the product. That they think I have to be bribed or blackmailed into buying it based on fuzzy feelings about something like AIDS or “the environment” or whatever. Since the business obviously knows their product very well, I trust their judgement that it is not good value and just buy someone else’s product instead.
Pathetic
This is the category in which many start ups fall and it’s been discussed here before. I’m not going to link the offending party who inspired today’s entry but suffice to say, most in this category practically beg for sales appealing to personal values. This usually falls in the vein of “I’m a good person, I recycle, I’m not a sweat shop, I give a[n undefined portion of the proceeds] to charity (assuming there’s something to give) and I’m uber cool, so buy my incredibly overpriced tee shirts”.
With a pitch like this, you haven’t sold anyone on the value of your product. How have you conveyed the value of it? If we want to support a charity, more of the money will go to the charity with direct checks rather than filtering it through you. These days you can’t be heard amid the clamor and din of everyone else who’s also making these claims. And even if this argument were convincing, it’ll take more than your propensity for buying organic fruit (in this particular case) to convince us of your social commitments. People are eco-fatigued. If you embrace this as your marketing strategy, you’re better off making a clean break and embracing cause marketing rather than this ambiguous pit. [Icing on the cake is that many of these sites feature copy comprised of 6 point font on flash pages with ambiguous navigation.] The point is, you must learn to disambiguate the value of who you are (a good person) from the value of your product. If you must rely on personal appeals and your product fails, it’s not that you’re a bad person; it’s that your product is likely mediocre and/or is poorly marketed.
Parasitic
The last of the three Ps is the least authentic. These are companies that develop products -nearly always a tee shirt- that are pegged or targeted to “awareness” of a particular infirmary. In other words, they sell shirts for autism awareness, cancer awareness, catering to a whole host of human frailties. I describe these appeals as parasitic because without the ailment, the product would have no reason to exist. In a manner of speaking, one has a vested interest in the continuation of the illness or condition for without it, there would be no revenue. If this is all your product has to stand on, you don’t have much going for you.
I don’t see products designed especially for said populations the same way. Based on the needs of unique populations, these aren’t parasitic but complimentary. Examples of worthwhile products designed around conditions are things like compression garments for burn victims, clothing designed to reduce tactile sensitivity or apparel designed to fit dwarfs or perhaps they prefer “little people” (pardon my ignorance, no deprecation is intended).
One last word of advice if you feel compelled to develop “awareness” products; is this something that the average “sufferer” would support? They’d probably prefer proceeds went to research or cures. Is it possible they could be offended or that you could be perceived as capitalizing on their infirmity? Is it possible the charity you’ve chosen to support is highly controversial in their community? You can’t assume it’s not. If you don’t do your homework, you may be surprised to find yourself the target of a boycott from the “victims” themselves. You may also be surprised to know that some people are offended that their “illness” is perceived to require a cure. It serves no purpose to have good intentions and subvert it all by creating ill will for your company where there had previously been none.
Related entries:
Naming a product line pt.69
Nurture people, not products (read the comments too)
Eco-Iconic
Related threads in the forum:
Labels and branding (strays a bit but an excellent thread)
Business and Charity, and marketing an image
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By Kathleen Fasanella on Nov 24, 2008 at 7:40 am
In reading the most recent issue of Science News (gated), I’m reminded of how I always giggle when someone describes silk as delicate or fragile. Did you know silks have six times the tensile strength of steel? Or that a silk cable, one inch in diameter, could pull a 747 from the sky? Regardless of how delicate designers think silk is, scientists have been long interested in its unique properties in part owing to its strength. Likewise, many insects other than silkworms make silk such as spiders, bees and ants.
As with anything, the issue is quality not quantity, and diversity. A single cocoon of the silkworms we’re most familiar with, can produce a single strand of silk 600 to 900 meters in length but spiders, only produce about 130 meters. Perhaps you’d think homogeneity would make for better research -silkworm silk is homogeneous- but the genetic diversity of spider silk is more complex and interesting. Spiders make five kinds of silk, most notably silk to wrap their egg cases, silk to wrap prey and web silk. Even the stage of insect development brings differences. For example, Weaver ants, another silk making insect, use silk produced by their larvae placing it here and there as needed (only baby weaver ants make silk, bringing new meaning to child labor).
Photo by Danielle Anthony
Of greatest interest to researchers is the golden silk spider (Nephila clavipes), a type of golden orb spider. They’re also prolific producers, with webs spanning a meter across. These are sometimes known as writing spiders due to the zig zag patterns in the center of their webs but these shouldn’t be confused with their cousin Argiope Aurantia most commonly described as the writing spider (although the one I photographed before could have been better described as illiterate or as someone said, had writer’s block or was writing x’s using cuneiform or another alphabet).
Spider silk has a great deal of potential from an environmental and safety standpoint. Among imagined applications are bulletproof vests (spider silk is stronger than Kevlar), scaffolding and linkages for use in surgery to grow cartilage and nerves.
The biggest problem with spider silk production is the nature of spiders. Unlike the placid silkworm suited to a mass production environment, spiders are antisocial predators who tend to eat each other if raised together. In this scenario, males always lose being very tiny in comparison to females. And with no males, there’s no baby spiders either.
Previously I’d mentioned that researchers were producing spider silk in goats milk. Science News says:
Lewis has collaborated with scientists at the Canadian firm Nexia Biotechnologies, part of the team that spliced spider silk genes into bovine cells in 2002 and later into goats. Today, transgenic goats roam at the University of Wyoming. While present in every goat cell, the spider silk genes are turned on only in the mammary glands, yielding goat milk laced with silk proteins. While promising, the yield is still low, Lewis says. A gallon of milk may have only 60 grams of silk, which means it would take about 600 gallons of milk to make one bulletproof vest. And there are still problems with purifying the proteins. After a few grams of silk have built up, the milk starts coagulating, perhaps because the silk proteins are binding to proteins in the milk, Lewis says.
Which circuitously, makes me grin when Mr. Fashion-Incubator pours Silk® over his breakfast cereal.
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By Kathleen Fasanella on Nov 21, 2008 at 3:16 pm
In the Wall Street Journal, Rick Woldenberg was quoted as describing February 10, 2009 as National Bankruptcy Day because that’s the day when many of us will go out of business due to the implementation of the CPSIA Regulations. I’m dismayed at how little it’s been discussed online and in the news. I’m shocked that so few manufacturers know about it. Of the ones that do know, most think it either doesn’t apply to them or it will magically disappear or it won’t be enforced so they can ignore it. Come February 10th, a lot of people will be hit hard by reality when their products are returned or their financing is declined.
To recap, this law was passed (424 votes to 1) to protect children from unsafe toys after last year’s widely publicized recalls (by the way, recalls have actually decreased by 46%). What few consumers realize is this legislation affects more than toys. What few clothing manufacturers realize is this also affects them. Of the ones who do know, most of them think it only applies to children’s clothes. Other than apparel the law includes diapers, blankets (housewares), books, videos, computer and electronic products, strollers, cribs, car seats, and anything humans come in contact with in their environment. Our objections are not higher standards for product safety or even the costs involved per se. The problem is Congress wrote the law and forced the CPSC to implement it before the regulations were written. These regulations are not written by people who are familiar with manufacturing and thus, impose unnecessary burdens.
A source I’m not at liberty to quote directly (but you can read it here) for legal advice -although she’s an attorney specializing in these matters AND an environmental engineer says
Another issue is lead paint limit. This limit applies only to painted or similar surface coatings - which would probably mostly be zippers, zipper pulls and perhaps buttons. This standard goes from 600 ppm (now) to 90 ppm. This applies for all painted materials for consumer use - not just kids stuff. I don’t know enough about your industry to know if this coating standard applies to painted on decorations on clothing. But, at the very least, any components of finished garments are going to have to meet this standard.
Three brief points:
- Regarding the phthalate regulations (a lengthy discourse omitted for brevity) testing for phthalates is roughly three times the cost of lead testing. For purposes of comparison, lead testing is expected to be about $30,000 for a ten piece line in three colorways.
- The lack of available labs needed to absorb the dramatic increase of testing required. Assuming everyone had the money and time to do it, it would still be impossible without the facilities and inspectors to do it.
- The requirement of “third party testing”. For our purposes this means you cannot avoid legal liability by relying on testing results supplied to you from your vendors. No no. You have to retest everything yourself. See why it’s problematic that these regulations were not written by those with a background in manufacturing?
Initially, we little guys were feeling a bit put out that these regulations would affect us a lot more than the big guys who have more money. As it turns out, they’ll be hurting in ways we won’t because they are factored. Selling to big box stores is done through loans, so called factoring. On the manufacturing side, loans are extended based on the receivables (invoices) that buyers owe the manufacturer. On the other side, factors lend money to stores to buy the inventory. Factors are a sort of financial middleman. Loans are more than just mere money changing hands; loans are legal contracts. To have a legal contract, the actions described within them must be legal. For example, a contract to hire a hit man is an illegal contract because the act of murder itself is illegal. Thus, loans for inventory and receivables cannot be legally extended unless the goods themselves are legal. Without the CPSIA compliance guaranty certificates, they won’t be.
Since most of the products intended for February delivery are either already made and on the way here or are in the process of being made and few to none of the inputs were tested beforeheand, all of these items will end up in bonded warehouses or landfills because it is illegal to sell them even as seconds. Products made domestically are not immune, they’re in the same boat. A factor is not going to break the law and make an illegal contract so a retailer can buy illegal goods. The end result is there will be a whole lot less product on store shelves. Since there won’t be much to pick from and costs are higher, consumers can expect to pay much higher prices. Prices will be rock bottom on February 9th, but overnight, prices will dramatically increase. The anticipated losses go into the hundreds of millions of dollars. This is not an exaggeration. According to 2002 U.S. Census Data (the last year for which data is available) just considering small U.S. clothing manufacturers, their contribution to the economy is over 900 million dollars annually. Small manufacturers with fewer than 20 employees comprise 68% of total apparel manufacturing in the U.S.. This of course does not include the untold numbers of stores that will go out of business too.
The point is now, what can we do? In the forum we’ve been devising a grassroots plan that we hope to launch tomorrow. One of our members who is familiar with regulatory processes, is drafting a letter you can mail to regulators. You can call your congressman. You can write a letter to the editor of any papers you read, on or offline. You can post about this on your own blog, post comments on blogs you read and talk it up in forums you belong to. You even need to lobby your suppliers too. Ask them what they’re doing about it. They’ll be hurting too if we’re not buying sewing machines or CAD systems. Resolve to post somewhere at least once a day.
The problem we have is that this is a very popular law with consumers and legislators. Because it is so complex, they don’t know what it really means or what its effects will be. In the upper echelons, most of the high level organizations like the AAFA, The Toy Association and the electronics industry are lobbying against it. Their problem is that they are not the grassroots. That’s you. The vast majority of Americans think this is a Great Law, striking back at unethically made low cost imports and thus, legislators are leery of what high level representatives say. That’s why it’s up to you to talk to other consumers like you. We need for consumers to know that this law will put many of us rather than importers out of business at a time when the economy can least absorb it. They need to know that come February, many of the products they expect to find in stores won’t be there. I think consumers will start to get the hint once they start getting tickets for transporting their infants without car seats because they can’t buy them in stores. Considering the consequences, there is little doubt the rules and regulations such as they are, will be rescinded. The only issue is, will they be rescinded before they bury too many of us? This law represents the last nail in the coffin of U.S. manufacturers. Even I’ll be out of a job. Why publish a blog if nearly no one can manufacture?
As I said, watch this space. I’ll be posting with more actions tomorrow.
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