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What is CPSIA?


CPSIA stands for the Consumer Products Safety Improvement Act, a law that was enacted in August of 2008 with the aim of improving product safety standards for products used by children.  It covers a wide range of products, virtually everything that would be sold to a consumer for use or wearing by children. 

CPSIA rules are complicated and have not been well explained to most manufacturers, it's been particularly hard for small manufacturers as they do not have ready (or inexpensive) resources to interpret and apply the complicated legal text.  The part that most matters to diaper makers is the Lead and Phthalate testing as they are slated to come into effect Feb 2011. 

Recently  CPSA has made some materials exempt and may provide exemptions for products made entirely from exempt materials.  Some camps believe CPSA has relaxed lead testing for in articles that use components that are certified, this is not the case for phthalates, and there is still some uncertainty on certifint the 'parts, and not the whole' article. 

What needs testing?

While there is no final rule on the definition of a “child care article” it is advisable to consider cloth diapers and cloth diaper accessories to be will legally be classified as such. That means they are subject to exemptions and certifications as required by the law, to call them anything else would be foolish.  As a 'child care' product, cloth diapers, wetbags, covers and swim diapers will require certification based on the materials used, and the style and construction. 

The best way to determine whether you need CPSA certification is to first evaluate your product against the exemption requirements.  If you're exempt, you will not technically require certification.  For the most part responsibility for certification lies with the manufacturer,  although importers and or retailers can secure certifications as well.

Step 1: Materials Test:

If a diaper is made made entirely from natural and/or synthetic textiles it may be may be exempt. from testing. 

Exempt Are not exempt
Most fabrics knitted or woven from Bamboo, Cotton, Hemp Polyester, Nylon, Acrylic, Wool, Zorb, spandex, lycra whether dyed or undyed. This includes knitted or woven elastics and hook-&-loop tapes. PUL, PUC or ProCare or any plastic or polymer coated fabric.  Printed fabrics, and fabrics with chemical  treatments (i.e wicking, UV protection)
Plastic or metal snaps, Plastic and/or metal zippers and pulls
Lastin or Mobilon elastics

If you diaper contains ONLY items in the left column EXEMPT, you are likely exempt.  If your article contains any items in the right column, proceed to Step 2, Construction Test. 

Step 2: Construction Test:

Articles made entirely from natural and/or synthetic textiles and constructed in a manner that non-exempt materials cannot come in contact with the child may be exempt. For instance an All-in-One diaper that has a pocket may be exempt if the pocket is lined in such a way that the plastic side of the PUL is entirely encased AND your closure is Hook & Loop.  If the pocket can be opened and the plastic side of the PUL can be touched, or you use snaps you will not be considered exempt.

Here's a short list of things that will by construction need certification:

  • Articles that are made with snaps
  • Articles than have plastic side of the barrier fabric (PUL, ProCare etc) exposed to touch on either side
  • Articles that use zippers and/or plastic cord locks
  • Articles that are processed in a way that may expose them to lead in processing   

Testing and issuing General Conformity Certificate (GCC)

If you have determined that you're product requires testing (or not), the next thing to do is organize the test.  Figuring out what you have to test is tricky too.  In most cases you will need to test one item from each unique style.  For instance, if you sell an AIO, fitted diaper and a wetbag, you would need to test all 3.  If you sell an AIO in 3 sizes + a One Size, a fitted and a wetbag, you will need to test one size of the AIO, one size of fitted and one size of wetbag. 

Once your product is tested to meet the standards by a CPSA approved third-party lab, you can issue a General Conformity Certificate (GCC) as a manufacturer (not a retailer). 

Note: CPSC now allows component testing for certain products for lead in paint standards, unfortunately this has confused many manufacturers into thinking component testing is acceptable for diapers -- it's not.  The relief is for paint standards and lead only, and since that standard does not apply to diapers etc,  there is no relief under this ruling for diaper makers.  The good news is it gives an indication of the direction CPSC might be heading and someday they may also allow component testing for Lead and Phthalates.

If you product is exempt from certification, you may still find it worthwhile to gain certifications.  Certification will make it easier to market your product, particularly in the early stages when many merchants have blanket policies that require all products be certified.   Importing or exporting diapering articles into the USA may be tricky without certification, particularly until Custom's brokers and CBP Officials gain experience with the law and how to clear exempt products.

What is Wazoodle doing?

As a textile manufacturer and distributor we are in the business of supplying materials.  As with most standards, it's the finished product that must be certified -- even when entirely assembled from certified components.  Having certifications on our materials doesn't help our manufacturing clients achieve their own certifications but we know it helps them eliminate uncertainties -- so we're helping by certifyung the core part of our diaper making product line.   The following items are in CIPSA testing now, we expect to have them all certified by Mid Feb.  Once we complete certification, we will offer General Conformity Certificates (GCC) on the following items:

  • Bamboo/Organic Cotton jersey, French terry, and fleece (completed in 2010)
  • DiaperMaker PUL
  • DiaperMaker Linings, Jersey and Pique
  • ProCare
  • LGB / Wazoodle Diaper Kits
  • LGB / Wazoodle Wetbag kits
  • KAM Snaps

In addition, we are providing low cost certification services through our partner test lab. Our goal is to make it possible for our small manufacturing clients to have their products conformance tested for lead and phthalates for less than $200/article.  We are working out the final details now, we hope to offer our customers a simple certification package available soon.   Stay tuned for more on this.

Mike
CEO, Wazoodle Fabrics

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