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