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Product Safety

Following the ever changing laws and regulations for children's products can be intimidating and confusing. That's why we've made it effortless for you. All of our children's products are tested and compliant with the Consumer Product Safety Improvement Act (CPSIA) and we can prove it! We are happy to provide general certificates of conformity (GCC)upon request.

What is the Consumer Product Safety Act?

The Consumer Product Safety Improvement Act (CPSIA) of 2008 is a United States law signed on August 14, 2008 by President George W. Bush. The legislative bill was known as HR 4040, sponsored by Congressman Bobby Rush (D-Ill.). On December 19, 2007, the U.S. House approved the bill 407-0. On March 6, 2008, the U.S. Senate approved the bill 79-13.[1] The lawpublic law 110-314increases the budget of the Consumer Product Safety Commission (CPSC), imposes new testing and documentation requirements, and sets new acceptable levels of several substances. It imposes new requirements on manufacturers of apparel, shoes, personal care products, accessories and jewelry, home furnishings, bedding, toys, electronics and video games, books, school supplies, educational materials and science kits. The Act also increases fines and specifies jail time for some violations.

What products are involved?

It is targeted mostly toward "children's products", which are defined as any consumer product designed or intended primarily for children 12 years of age or younger. There are also new rules governing All terrain vehicle (ATVs). It also affects any product that is subject to anything the CPSC regulates by requiring certificates of conformance which state that the product was tested to conform to the regulations it is subject to.

What is the definition of a children's product?

The law defines a "children's product" as a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, the following factors will be considered:

  • A statement by the manufacturer about the intended use of the product, including a label on the product, if such statement is reasonable.
  • Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger.
  • Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
  • The Age Determination Guidelines issued by the Commission staff in September 2002, and any successor to such guidelines.
See 15 USC 2052 See also 16 CFR 1200.2(a) For the CPSC's detailed analysis about the four factors, see 16 CFR 1200.2(c)

Testing for Lead

The legislation reduces the limit of lead allowed in surface coatings or paint to 90 ppm (from the current limit of 600 ppm) effective on 14 August 2009.
The legislation reduces the amount of total lead content in children's product substrates to:

  • 600 ppm by 10 February 2009
  • 300 ppm by 14 August 2009
  • 100 ppm by 14 August 2011

Testing for Phthalates

As of 10 February 2009, it shall be unlawful for any person to manufacture for sale, distribute in commerce, or import any children's toy or childcare article that contains the phthalates DEHP, DBP, or BBP at levels higher than 0.1 percent.
The legislation bans from any children's toy that can be put in a child's mouth or childcare articles phthalates DINP, DIDP, and DnOP at levels higher than 0.1% on an interim basis until a report from the Chronic Hazard Advisory Panel (CHAP) is received, after which the CPSC can continue the prohibition by rule.

Mandatory Testing

The legislation requires that every manufacturer of a product subject to a consumer product safety rule will provide a "General Conformity Certificate" (GCC) to certify, based on unit testing or a reasonable testing program, that the product complies with all safety rules. This requirement was imposed on every product manufactured on or after 12 November 2008. The certificate must:

  • Be in English
  • List the name, address, and phone number of the manufacturer, importer, and/or private labeler issuing the certificate and any third party testing facility
  • List the date and place of manufacture and date and place of testing
  • List the contact information of the records keeper
  • List each applicable rule, standard, and ban

How do I obtain a General Certificate of Conformity?

Simply contact us and we will provide all of the pertinent documentation your client will need.

What about Prop 65 compliance?

Mi Line by Fey obtains information from our suppliers regarding the composition of components and performs independent testing for lead.

Chemicals listed by the State of California, if present, are in such low levels in our finished products that normal handling and reasonably anticipated and intended use of our advertising and promotional vehicles would result in no or minimal exposure and therefore have "no significant risk" or "no observable effect" as defined by Proposition 65.

Because of that, none of the Reflectix by Fey products require Proposition warning labels.