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What are we supposed to do?

 
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Kris Kranz
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PostPosted: Fri Feb 24, 2012 10:45 pm    Post subject: What are we supposed to do? Reply with quote

I have been reading all the different places that have info about this, and when Kathleen sent out the message to register right now, I didn't even have a company name to register.

Now I am re-reading and considering registering, but I have to admit, I really don't understand what this all means. IF I register then I still need to provide a document that says the garment is in compliance with the law?

What do I gain, by registering, if I still need to prove that I am complying with the rules the CPSC has set forth?

Do I merely shift the requirement to prove that this is a compliant product to testing that someone else has to do, so now I can only buy "ingredients" for my garments from places that ship a GCC with every order?

This is very FRUSTRATING. I apologize if I haven't done enough homework to get this. I am not trying to waste anyone's time, but could someone point me to the place where I can get a straight answer on this? Or is that the crux of the problem, this doesn't make sense and that is that? Then if that is the case, what are the costs of not registering?
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Esther
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Joined: 17 Mar 2006
Posts: 1864
Location: ID Spudville

PostPosted: Sun Feb 26, 2012 8:57 am    Post subject: Reply with quote

That is the dilemma every one is facing. If you register, you are on a list that the CPSC or any gorilla consumer protection advocacy can use for whatever nefarious or ridiculous reasons they can come up with. I haven't seen any benefit to registering that justifies the exposure. On the other hand, if you don't register and something happens, then it may look like you haven't done your due diligence in following the law. It's a Catch-22.
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Kathleen F.
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Joined: 08 Sep 2005
Posts: 10756
Location: NM Albuquerque

PostPosted: Sun Feb 26, 2012 11:12 am    Post subject: Reply with quote

As far as I know, the list isn't public. It does provide some benefits with respect to being able to use your supplier's certification which reduces some duplicate testing.

You will need to provide a GCC regardless. The only way someone provides a GCC to you is if you're buying products that are retail-ready. What I think you mean is whether an "ingredients" supplier provides their testing results to you. Obviously you're limited to suppliers who will do that.

Regardless of whether you apply for the program or not, you need to comply with the law.
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Kathleen Gerber
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PostPosted: Sun May 13, 2012 12:07 am    Post subject: Reply with quote

One benefit of registering is, if you are selling less than $1million a year in product, you can apply for a small batch exemption (at least with children's clothing)

As far as suppliers of components - I am choosing to spend a little extra and use ykk zippers. They are manufactured in the US, and they supply the distributers with the proper paperwork, who will (or should) in turn give you a copy.

It's a pain to read through all the legal dialect of the different codes and sections, but they do have a link where you may email your questions.

Below is a question I emailed, along with the detailed response I received:

QUESTION
Hello: I am producing a line of girls clothing. if I purchase my zippers from a vendor, and the vendor provides documentation that they are CPSIA compliant children’s zippers, need I still test the final product? (dresses for girls aged 2-Cool thank you

ANSWER
Not necessarily. The Commission has created a rule on component part suppliers. If the vendor provides you with a Children’s Product Certificate (CPC) that complies with that rule, then you do NOT need to retest it and can use it as the base for issuing your own CPC. See www.cpsc.gov/3PT .

If you a registered small batch manufacturer, you likely do not need to test the zippers if the manufacturer has provided you with written assurances of its compliance that you can then use as the basis for issuing your CPC. See www.cpsc.gov/smallbatch. The materials still must comply but third-party testing may not be required. (If the zippers are painted, then they will required testing. If the zippers are metal or poly-resin with no surface coating, then the above advice would apply.)

I hope this is helpful to you. Please contact me with any additional questions.

Sincerely,

Neal

Neal S. Cohen
Small Business Ombudsman
U.S. Consumer Product Safety Commission
Tel: 301.504.7504
ncohen@cpsc.gov
www.cpsc.gov/sbo
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Melissa Schworer
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Joined: 16 Mar 2016
Posts: 138
Location: ID Nampa

PostPosted: Tue Mar 29, 2016 10:00 pm    Post subject: Re: What are we supposed to do? Reply with quote

Kris Kranz wrote:
I have been reading all the different places that have info about this, and when Kathleen sent out the message to register right now, I didn't even have a company name to register.

Now I am re-reading and considering registering, but I have to admit, I really don't understand what this all means. IF I register then I still need to provide a document that says the garment is in compliance with the law?

What do I gain, by registering, if I still need to prove that I am complying with the rules the CPSC has set forth?

Do I merely shift the requirement to prove that this is a compliant product to testing that someone else has to do, so now I can only buy "ingredients" for my garments from places that ship a GCC with every order?

This is very FRUSTRATING. I apologize if I haven't done enough homework to get this. I am not trying to waste anyone's time, but could someone point me to the place where I can get a straight answer on this? Or is that the crux of the problem, this doesn't make sense and that is that? Then if that is the case, what are the costs of not registering?


THIS ENTIRE QUOTE ... is what I am currently wondering. Has anything cleared up. Is there a straight answer on this yet?

I am looking up the page and about the Small Batch FAQ, and wondering if I need to register or if on my label I can just refer to my own data?

Or is that not good enough because I need to make sure that my fabric and materials are all tested? I am so confused?

I am trying to read everything, but I am still sooooooo confused?

Does anyone have any clarity they can offer?
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