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Specialized Technology Resources, Inc.

Specialized Technology Resources, Inc. CPSIA for Textiles and Apparel. January 22, 2010.

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Specialized Technology Resources, Inc.

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  1. Specialized Technology Resources, Inc. CPSIA for Textiles and Apparel January 22, 2010 This presentation is based on the best available information as of this webinar.  As interpretations and clarifications of the CPSIA requirements continue to evolve, the information included in this presentation may change.  STR continues to monitor the CPSIA closely and to provide recommendations and consultation to our valued clients based on the best available information. Raising the world’s expectation of product quality, safety and supply chain responsibility

  2. Signed on August 14, 2008 http://www.cpsc.gov/ABOUT/Cpsia/cpsia.HTML Under the jurisdiction of the Consumer Product Safety Commission Since enactment, CPSC has held various public meetings and has issued numerous advisory opinions, test methods, guidance documents and Federal Register notices. This work session covers the latest updates through January 10, 2010. Consumer Product Safety Improvement Act of 2008 for Apparel

  3. Three U.S. Agencies Apparel Producers Must Know Consumer Product Safety Commission Flammability CPSIA Federal Trade Commission Care Labeling Content labeling U.S. Customs and Border Protection –CBP Import Regulations US Government Federal Agencies

  4. http://www.cpsc.gov/ The U.S. Consumer Product Safety Commission is charged with protecting the public from unreasonable risks of serious injury or death from thousands of types of consumer products under the agency's jurisdiction. The CPSC is committed to protecting consumers and families from products that pose a fire, electrical, chemical, or mechanical hazard or can injure children. The CPSC's work to ensure the safety of consumer products - such as toys, cribs, power tools, cigarette lighters, and household chemicals - contributed significantly to the 30 percent decline in the rate of deaths and injuries associated with consumer products over the past 30 years. CPSC

  5. http://www.ftc.gov/ When the FTC was created in 1914, its purpose was to prevent unfair methods of competition in commerce as part of the battle to “bust the trusts.” Over the years, Congress passed additional laws giving the agency greater authority to police anticompetitive practices. In 1938, Congress passed a broad prohibition against “unfair and deceptive acts or practices.” Since then, the Commission also has been directed to administer a wide variety of other consumer protection laws, including the Telemarketing Sales Rule, the Pay-Per-Call Rule and the Equal Credit Opportunity Act. In 1975, Congress gave the FTC the authority to adopt industry-wide trade regulation rules FTC

  6. http://www.cbp.gov/ CBP is one of the Department of Homeland Security’s largest and most complex components, with a priority mission of keeping terrorists and their weapons out of the U.S. It also has a responsibility for securing and facilitating trade and travel while enforcing hundreds of U.S. regulations, including immigration and drug laws. CBP

  7. CPSIA General

  8. The CPSIA was passed in reaction the to the many (toy) recalls in 2007. Millions of toys were recalled due to excessive lead in paint. In this webinar we will focus on those aspects of CPSIA which affect apparel in specific and softlines in general. Most of the regulations were intended to be in effect by now – but the US Government through the CPSC has issued “stays of enforcement” postponing certain requirements. What is the CPSIA

  9. CPSIA in General CPSIA- Testing for Apparel Tracking Label Documentation Q & A Session Agenda

  10. Sections most applicable to Apparel; Section 101 – Children’s Product Containing Lead; Lead Paint Rule Section 102 – Mandatory Third Party Testing for Certain Children’s Products; General Conformity Certificate Section 103 – Tracking Labels for Children’s Products Section 105 – Labeling Requirements for Advertising Toys & Games Section 106 – Mandatory Toy Safety Standards Section 108 – Prohibition on Sale of Certain Products Containing Specified Phthalates CPSIAChildren’s Product Safety, Including Apparel

  11. Consumer Product – Any article, produced or distributed (i) for sale to a consumer for use or (ii) for the personal use, consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or otherwise Children’s Product – Consumer product designed or intended for children 12 years of age or younger. Children’s Toy – Consumer product designed or intended by the manufacturer for a child 12 years of age or younger for use by the child when the child plays Child Care Article – Consumer product designed or intended by the manufacturer to facilitate sleep or the feeding of children age 3 and younger, or to help such children with sucking or teething CPSIA Definitions

  12. You first must understand what product category your garment is in! Consider the age appropriateness of your product How will your product be merchandized or placed at retail? How is your product embellished? Are the logos common or appropriate for a child? Definitions are Important – Things to Consider

  13. Does not Postpone compliance with the 2/10/09 requirements. Stop the testing and certification requirements from going into effect but merely postpones them. Postpone the testing and certification requirements which have already been implemented. Does Provide opportunity for CPSC to establish rules needed for implementation of the lead provisions. Provide CPSC time to rule on exemptions and exclusions from lead, and develop an approach to component parts testing. Provide CPSC an opportunity to provide detailed guidance on how to comply with requirements. Stay of Enforcement of Testing & Certification Requirements for Certain ProductsUntil February 2011.

  14. Original CPSIA Schedule for Mandatory Third Party Testing & Certification for Certain Children’s Products

  15. Stay not extended for Youth bicycle helmets Bunk beds Infant rattles Dive sticks Stay extended for all other children’s products, and GCC’s are Not Required until third party testing becomes mandatory December 18, 2009:CPSC Extends the Stay of Enforcement on Testing & Certification Requirements for Many Children’s Products

  16. Mandatory Third Party Testing & Certification of Children’s Products Currently Required Lead in Paint Cribs Pacifiers Small Parts Lead in Children’s Metal Jewelry Cadmium is now getting great attention by the CPSC

  17. CPSIA for Apparel

  18. Textile Flammability (All Consumer Products) Lead in painted surfaces applied to clothing (Children’s Products) Lead in textile substrates (Children’s Products) Phthalate testing in certain apparel products (Child Care articles) Certification mandated by the CPSIA legislation Tracking labels for apparel products (Children’s Products) CPSIA – Apparel and SoftlinesYour Concerns

  19. 16 CFR Part 1610 for Adult Wearing Apparel Compliance is required GCC is not required unto Feb 10, 2011 Third party testing is not required 16 CFR Part 1615 and Part 1616 for Children’s Sleepwear (loose fitting) Compliance is required GCC is not required until Feb, 2011 Third party testing is not required Flammability Pre- CPSIA

  20. 16 CFR Part 1610, provides for certain fabrics to be exempted from testing based on the fiber content, fabric weight and finished fabric properties. FlammabilityExempt Fabrics

  21. December 10, 2009Release # 10-063 Firm's Recall Hotline: (877) 649-4386CPSC Recall Hotline: (800) 638-2772CPSC Media Contact: (301) 504-7908Children's Pajama Sets Recalled by Little Miss Matched Due to Violation of Federal Flammability Standard WASHINGTON, D.C. - The U.S. Consumer Product Safety Commission, in cooperation with the firm named below, today announced a voluntary recall of the following consumer product. Consumers should stop using recalled products immediately unless otherwise instructed. Name of Product: Little Miss Matched Girls Pajama Sets Units: About 7,000 in the United States and about 288 in Canada Importer: Little Miss Matched Inc., of New York, N.Y. Hazard: The sleepwear fails to meet the federal children’s sleepwear flammability standard posing a risk of burn injury to children. Incidents/Injuries: None reported. Description: This recall involves long sleeve toddler and girls pajama sets. The sets were sold in sizes XXS (2t-3t), XS (3t-4t), S (5-6), M (7-8) and L (10-12), and in three varieties: BlackMulticolored stripes/polka dotsWhiteMulticolored stripes/polka dotsPinkBlue stripes and oversized polka dotsSold exclusively at: Various retailers nationwide from March 2008 through July 2009 for between $30 (U.S.) and in Canada from March 2008 through November 2009 for about $30 (CAN). Manufactured in: Honduras Remedy: Consumers should immediately stop using the recalled pajamas and contact the firm to receive a full refund. Recent Recall for Flammability

  22. From CPSC Website

  23. Section 101Children’s Apparel Containing Lead- Lead Paint Rule

  24. Is the paint “scrapable”? Applies to children’s products, furniture, paint i.e. Painted Zippers, Buttons, Screen Printing Existing Ban as of August 14, 2009 16 CFR 1303 in effect since 1978 at 600 ppm As of August 14, 2009, sets limit at 90 ppm Compliance is required GCC is required Third party testing is required Composite Testing is allowed Wet paint can be tested Children’s Apparel - Lead in Paint

  25. January 8, 2010Release # 10-105 Firm's Recall Hotline: (800) 347-9411CPSC Recall Hotline: (800) 638-2772CPSC Media Contact: (301) 504-7908 Children’s “Big Rex and Friends” Cloth Books Recalled Due to Risk of Lead Exposure WASHINGTON, D.C. - The U.S. Consumer Product Safety Commission, in cooperation with the firm named below, today announced a voluntary recall of the following products. Consumers should stop using recalled products immediately unless otherwise instructed. Name of Product: "Big Rex and Friends" Cloth Books Units: About 204,000 Importer: St. Martin’s Press LLC, of New York, N.Y. Hazard: A red plastic dot sewn in the book contains high levels of lead. Lead is toxic if ingested by young children and can cause adverse health effects. Incidents/Injuries: None reported. Description: This recall involves “Big Rex and Friends” cloth books. The book has a black and white striped border with a red dinosaur on the cover. The words “Big Rex and Friends” are printed on the cover. ISBN 031249260X or 9780312492601 is printed on the back of the book. Sold at: Barnes & Noble, Toys “R” Us, Amazon, Borders and other bookstores and retailers nationwide from May 2004 through October 2009 for about $9. Manufactured in: China Recent Recall for Lead in Paint

  26. From CPSC Website

  27. The CPSC did issue an updated test method for determining lead in painted surfaces which includes an allowance for composite testing meaning up to three paint colors on a product can be tested in one analysis, provided certain parameters are met. requirement for equal amounts of color sensitivity of the laboratory equipment correction factors. STR worked with other laboratories to develop recommended composite test protocol. Wet Paint testing is allowed – BUT STR does not recommend this as the sole testing program Composite is not allowed for lead in substrate. CPSIA- Composite Testing for Lead in Paint

  28. A substrate is the material of which something is made, and to which surface coating may be applied (Buttons, Rhinestones, Zippers) As of August 14, 2009 - 300 ppm limit Compliance is required GCC is not required (Feb 10, 2011) Third party testing is not required Composite testing is NOT allowed Resin testing is allowed – BUT STR does not recommend as the sole testing program. As of August 14, 2011 - 100 ppm limit is possible Children’s Apparel Containing Lead in (Accessible) Substrate

  29. Lead Content in Substrate Does not apply to textiles, dyed or un-dyed Screen printing has not been exempted and most be tested. Does apply to plastic zippers/ buttons/snaps, rhinestones, sequins, garment labels, leather, vinyl, PVC, etc. Requires compliance. Third party testing and certification are currently under the stay of enforcement until Feb 10, 2011 Children’s Apparel Containing Lead in (Accessible) Substrate

  30. You may be using jewelry as an accessory CPSC interim policy for children’s metal jewelry has been replaced with CPSIA Lead Content requirement as of 2/10/09. Certain states require lead compliance for adult jewelry as well as children’s jewelry. The request for exclusion from the Fashion Jewelry Trade Association for exemption of crystal and glass beads, was denied. Lead in Substrate - Jewelry

  31. CPSC has recently released following study results; “Study on the Effectiveness, Precision, and Reliability of X-ray Fluorescence Spectrometry” – August 2009 Lead in Paint – XRF technology is not suitable to meet CPSIA testing. The wet chemical test is required. Lead in Substrate – XRF technology is suitable to meet CPSIA testing, when substrate is a polymer. Lead Testing and XRF Technology

  32. Section 102Mandatory Third Party Testing for Certain Children’s Apparel General Conformity Certificate or Certificate of Compliance

  33. Applies to product manufactured on or after November 12, 2008 Applies to consumer products covered by CPSC-enforced regulations Certificate is responsibility of Importer (if produced outside US) or Domestic Manufacturer (if produced within US) Mandatory Third Party Testing Required for certain Children’s Products There is a suggested format available on the CPSC website. You can tailor this to suit your needs as long as you meet reporting requirements. The stay of enforcement extends the testing and certification date for certain categories CPSIA General Conformity Certificate/ Certification of Compliance

  34. Section 103Tracking Labels for Children’s Apparel

  35. Permanent, distinguishing marks on product (to the extent practicable) and packaging manufactured as of August 14, 2009 Required for all children’s products and applies to both imported and domestically manufactured products. Allows the ultimate purchaser to ascertain the Manufacturer or private labeler name Location and date of production Other cohort information (batch, run number, sources) Tracking Labels for Children’s ApparelSection 103

  36. The CPSC has not issued guidance; on what is meant by “to the Extent Practicable” on the size and location of the label The Federal Care Labeling rules can be a guide on what is practicable labeling. When evaluating your labeling, the CPSC will consider the reasonableness of your marking/labeling decision and consider the practices of your peers. Therefore; In general, marking on hangtags or adhesive labels do not meet the “permanent” requirements for most apparel. Some items such as Socks/Hosiery do not follow the Federal Care Labeling rules. Tracking Labels for Children’s ApparelSection 103

  37. When is it not practical to sew in a permanent label? It is not practical to use a permanent tracking label on socks because socks are unable to be marked directly with a country of origin label. Tracking label should appear on the packaging.

  38. Section 103 does not require a uniform “one size fits all” labeling system. The only uniform requirement is that the tracking information required by the statue be ascertainable from the distinguished marks made on the children’s product and packaging. How an individual manufacturer chooses to achieve this is left to the reasonable judgment of each manufacturer, until the CPSC decides to implement more detailed and uniform regulations. Tracking Labels for Children’s ApparelSection 103 - Guidance from the CPSC

  39. Section 108Prohibition on Sale of Textile Products Containing Specified Phthalates

  40. Applies only to Children’s Toys and Child Care Products, including textile products. For all such products DEHP, DBP, BBP are not allowed in concentrations exceeding 0.1% For all such products or any part of the product, that can be placed in a child’s mouth: DINP, DIDP, DnOP not allowed in concentrations exceeding 0.1% (interim prohibition) Requires compliance. Third party testing and certification are currently under one the year stay of enforcement Prohibition on Sale of Certain Products Containing Specified Phthalates – Section 108

  41. CPSC issued new test method Requires component testing rather than entire toy Materials that are not plasticized do not require testing Harmonization to Europe and California phthalate regulations Phthalate Updates

  42. Reasonable Testing Program has yet to be defined by the CPSC and interim direction was released in December 2009. Per the CPSC, the goal of a reasonable testing program is to provide “reasonable certainty that all manufactured products comply with rules, standards, and bans.” A Reasonable Testing Program has five essential elements; Product Specifications Certification Testing Production Testing Remedial Action Plan Documentation Future CPSC Guidance

  43. As of August 14 Tracking labels are required for all Children’ products The lead in paint limit is 90ppm The lead in substrate limit is 300ppm The “Stays of Enforcement” expire on February 10, 2011 STR Highly recommends that you prepare now A GCC, supported by testing will be required Key Points

  44. Monitor CPSC website (www.cpsc.gov) Sign up for CPSC email alerts on CPSIA Monitor STR’s website for CPSIA FAQ (www.STRQuality.com) Sign up for STR Monitor Newsletter and News Alerts Keeping Informed

  45. If you have further questions please contact Ben DeVito at: Ben.DeVito@STRQuality.com STR also has a CPSIA “Frequently Asked Questions” section on our websitewww.STRQuality.com and sign up for our newsletter the STR Monitor Thank You Q & A Session

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