It is time to look at our materials. This is probably one of the three most overwhelming parts of the whole process (the other two being tracking and the certificate of compliance). The nice thing is that we can ask ourselves a few questions to determine some of the things we may need. Let's begin.
Is it a clothing item (include things like scarves, aprons, hats, bibs, and cloth diapers)?
- Then we need to look at flammability of wearing apparel. This is not the same as sleepwear flammability (leave this for another day, we can chat about it later).
- Leave the fuzzy stuff (think: flannel, velour, french terry, corduroy) alone unless it is made of only: polyester, acrylic, modaacrylic, nylon, olefin, or wool. If it is flat (think: knit t-shirt or quilting cotton) or made of only those previously mentioned fibers, then you can use it for any clothing.
- If the component is hidden, then it is exempt from lab testing.
- We need to focus on lead. There are three types to look at: textiles, paints, and "other".
- In textiles, there isn't much to watch out for because of the long list of exempted fibers. Chances are, if you've heard of the fiber & it is commonly used, it is exempt from lab testing.
- With paints, we want to stay away from things where the paint can be scratched off or cracks when stretched.
- The "other" is things like plastic buckles, snaps, buttons, zippers, etc. and they do require lab testing, so shy away from those if you can.
- Again, if the component is hidden, then it is also exempt from lab testing so long as the item does not break apart easily thus exposing that hidden area.
- This only applies to anything plasticized. The most common components are snaps and polyurethane laminate. A new update with the CPSC has permitted some allowance for not testing, but you will need to know exactly what phthalates were used in the manufacturing process.
- There are additional requirements for toys utilizing the ASTM F963-16 publication.
- The most popular requirements deal with use and abuse testing, heavy chemical testing, and small part testing.
If you completed step one, registration, then let out a breathe of relief. As a registered small batch manufacturer (your registration number looks like ######-######), you are permitted some allowances to reduce the financial burden of lab testing on some things.
If your material requires flammability or lead testing, you can contact your supplier and ask if they have already had the testing you need done. All you need is trust in your supplier and a specific statement (make sure it states the component you are asking about and the test(s) conducted).
Paint and "other" testing:
If your textile or notion requires testing for paints, you can contact your supplier and ask if they have already had the testing you need done. You need the testing results of the item and the test you are requesting.
All tests must be conducted under the CPSC-approved lab tests. For example, EN (European) or OEKO-Tex testing may not be sufficient for your records. You may assume, but you hold the responsibility to make sure you have the correct tests. Proprietary information (your supplier's manufacturer for example) may be blacked out.
Any material change in a component that requires testing creates a necessity to retest. Periodic testing is also required. Best practice is yearly so if you are obtaining statements from your suppliers, I encourage you to get a new statement from them every year (put the date at the top of the statement so you know which year you obtained it).
NOTE: "Exemption" is only from testing. You will still need to comply with any labeling and documentation requirements.