After starting the blog recently with such gusto, it’s been rather neglected in the last few weeks (hopefully I can now get back on track with it again). There’s a very good reason for that though because I have been incredibly busy going through the process of becoming compliant. This is a complex, but important safety measure, which was a lot of work, and VERY time consuming, but I’m delighted to say now that all my children’s products are now fully compliant.
So, what is safety compliance?
Safety compliance is a requirement for anyone selling products for children 12 years old or younger to customers in the USA, regardless if they are a small, home business, or a major chain store. In fact, products need to be compliant if they are given as gifts or donated too. Compliant products ensure that customers can purchase items that are made with safety in mind so that your family can be kept as safe as possible allowing you to shop with peace of mind.
Although based in the UK, I do ship worldwide, so it is important that my products comply with other countries' rules and regulations. Product safety requirements and laws in the States are much more stringent than here in the UK, particularly for children’s products. Safety compliance is regulated by the Consumer Product Safety Commission (CPSC) and Consumer Product Safety Improvement Act (CPSIA) in the USA. Under these regulations, nearly all children’s products must be tested for a variety of elements to ensure the safety of children. The elements include lead, flammability and phthalates (which are substances added to plastics to increase their flexibility, transparency, durability, and longevity).
Who should be compliant?
ANYONE who sells products for children to the USA needs to be compliant by law, regardless of what country they reside in. Not surprisingly, there aren’t that many handmade businesses in the UK that are compliant, despite selling to the US. More surprisingly, there’s a large percentage of US business that aren’t compliant either and don’t even appear to know about this aspect of consumer law.
How do I know if a business or product is compliant?
Most likely, if a business is selling compliant products on the internet, they will have it stated clearly that they are compliant in several places. There aren’t going to be many business owners who will go through such a long process and then neglect to prominently display it on their website. You should be looking for phrases such as ‘Meets CPSC Safety Requirements’. If you are looking at a children’s product in person, you will be able to see if the item is compliant by its labelling. Legally, these products need to have certain information permanently attached including:
- Business name
- Business contact (usually website)
- Where it was made
- Date of manufacture (may just be month/year)
- Care instructions (in symbols or writing)
- A unique tracking number to enable product recall
Other details such as fiber content and size can be on a separate hang tag.
What does becoming compliant involve?
There are various stages to go through methodically and thoroughly to become compliant. Briefly, these are the steps that I took:
1) Register as a small batch manufacturer.
2) Sort through any existing materials and notions to check that they are compliant (this means that they don’t require testing for lead, flammability and phthalates). When purchasing supplies that require testing, contact suppliers and find out if they can supply test certificates for them - some materials may need lab testing.
3) Create unique reference numbers or a code for each item which will be updated every time that supply is replaced.
4) Create a materials inventory and log item/reference number/date purchased/purchased from/cost/fibre content/exemptions. This will be added to each time a new supply or replacement supply is purchased.
5) Work out how many different tracking labels you will need (you need to make sure that you have enough to cover all care instructions).
6) Design and order tracking labels to permanently attach to finished items.
7) Write Children’s Product Certificates (CPCs) for each item type which includes detailed information including citations to any CPSC regulation that applies to each product and any exemption codes. These need to be produced monthly and kept for 5 years.
8) Keep a record of finished products with tracking details also included on the sew in tags. The tracking details include the date of manufacture (DOM) and batch number - this consists of a code the represents all components and materials used to make that item.
Do you need help to become compliant too?
Start with the US Safety Compliance FB group where there are detailed files on the compliance process. There is ridiculously little information out there specifically about how to become compliant. This group is incredibly helpful and supportive and I highly recommend joining if you need to become compliant too.
Want more help?
I am by no means an expert, but having just finished this process, I can probably answer most simple questions that you may have, or at least point you in the right direction so that you can find the answer. So, please do pop your questions in the comments – I’m happy to help if I can!
I am also planning to do a ‘how to’ blog post very soon, which will guide you through the exact steps I took to become compliant step-by-step.