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How small businesses have some wiggle room in testing costs

Written by Misty Henry

Updated 3 months ago

One of the first things I see people talk about when approached about product safety laws is the expense.

"Many small makers aren't following CPSC because it's too costly!"

Yikes!

Well, let me tell ya that this isn't an excuse. I mean, nothing is an excuse to blatantly ignore the law, especially when those laws are here to (mostly) protect children.

"But, seriously, it's so expensive!" - Is it though?

There are many exemptions from testing that the CPSC automatically provides because, after years and years of consistent testing, there are many products that clearly pass each time.

For example: Children's clothing may not need any testing at all because the fabrics that are typically used would be exempt from Total Lead Content due to fiber content and exempt from Flammability testing due to being plain surfaced material. Clothing is also exempt from Small Parts testing if they have snaps or buttons because the CPSC understands that such pieces must be small in order to function.

So, there's no testing which means no extra expense outside of having proper labeling (which you should for branding anyway) and time.

"But everyone talks about testing. Why do they talk about it if it's not a thing?"

Well, testing is a thing, just not always a thing.

For example: Children's clothing that has plastic snaps on it must have testing done on that snaps, usually in all colors.

This is where the expense can come in, and this is where you can save a little money by not having to test.

All businesses, regardless of size, should be registered to have an account with the CPSC at SaferProducts.gov. In this account, the business is able to quickly report and respond to reports of non-compliance or injury.

Small batch makers, though, have an added part of the registration that allows them to not test everything on their own.

And this registration is free.

When you go to SaferProducts.gov and register, for free, as a Small Batch Manufacturer, you are allowed some wiggle room in meeting the regulations.

Yes, you still must comply with all of the regulations, but instead of testing those plastic snaps for Total Lead Content on your own at a lab, you may utilize a trusted statement from a supplier that the appropriate testing has already been done and the component has passed to be used for a children's product. You just saved at least $100+.

Now, you can do this with nearly anything that will not change after testing during your own manufacturing process. This applies to:

Total Lead Content
Phthalates
Heavy Elements
Flammability
Lead in Paints and Other Similar Surface Coatings*

*NOTE: You must have an actual report, from a CPSC-accepted lab, that is under a year old for your exact component. This is one that you must have the hard proof in your own records.

Things that you will still have to test on your own are:

Small Parts
ASTM F963**

**NOTE: ASTM F963 is the General Toy Standard that the CPSC uses for all children's toys. This publication is large and covers a wide variety of toys. Many tests within the publication can be reasonably done at home instead of at a CPSC-accepted lab. You must be able to properly conduct the tests as outlined in the ASTM F963 publication and many things that a small batch at-home maker would need to do are usually fairly simple with some hardware, a tote bag, and soup cans.

You must still comply with all of the regulations, but this free Small Batch Manufacturer registry allows some wiggle room.

The number that you'll receive will go on your Children's Product Certificate which is the document that outlines exactly how your product complies with all of the regulations. In this case, you may have your own third-party (lab) testing, first-party (at-home/in-house) testing, supplier statements, and exemptions.

Click the link above.
Follow on-screen instructions to fill out the information
Respond to email with 'yes, this is a correct email for responding'.
IF a 'letterhead request' is sent, respond within the email (no 'letterhead' required) that you are the owner of X Business and have full authority to receive and respond to any complaints or questions.
Log into your account at SaferProducts.gov, click the tab in far right that says "Small Batch Manufacturer" and find your number.
Renew every January.

Links to Agency Resources

- Federal Trade Commission: What requires labeling of fiber content?, Clothing care information
- Customers & Border Protection: Country of origin markings
- Consumer Product Safety Commission: Small Business Assistance

More Assistance

If this was a lot, don't worry, it is and I understand that! That's why I have created a free course that walks you through the basic process, step-by-step.

Get the free course here.

Join my free Facebook group, US Product Safety Compliance.
The Makers Community memberships.
Free Checklist.
Free basic product safety course.

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