ECO-T Environmental Sustainability Plan

CPSIA 2008 Compliant

Consumer Product Safety Improvement Act of 2008

The Consumer Product Safety Improvement Act of 2008 (CPSIA 2008) was enacted in August of 2008 for the purpose of reducing toxic chemicals in products and providing consumer knowledge about the products they use. We feel this law is a great first step to insure the products we all use are safe. The CPSIA outlines a series of testing steps that products must go through and dates of compliance for specified levels of toxic chemicals. Please visit the CPSIA site for up to date information.

What products does the CPSIA cover that a screen printer carries? Everything. Although most of the CPSIA is focused on toys and baby items, it also covers children's products. Children's product is defined as any item marketed or intended for use by a child 12 years or younger. This includes all items from sneakers to straws, and apparel and happy meal boxes, you name it and if there is the expectation of a 12 year old using it, it's covered. Any screen printer that offers youth size shirts or even up to adult medium sized t-shirts must comply with the CPSIA rules.

What are the rules for children's products like t-shirts?

1. Lead content of less than 0.03% by 8/09, 0.01% by 2011
2. Lead content of less than 0.009% in all coatings like ink
3. Testing must be done by a third party certified lab to verify the amount of lead. Companies cannot rely on the word of the supplier, each company must get its own testing done.
4. Third party conformity certificate shipped with each order of product.
5. Every single children's product must have a tracking label by August, 2009.

CPSC Timetable [PDF, opens in new window]

Retesting Every Combination

The rules are very specific on testing, when a variable changes, you must retest. So if you are making a Spiderman^® action figure and then a doll or even a smaller Spiderman^® mini with the same ink and plastic batch, you must still third party test both. The rules are not clear on custom short run products like Build-a-Bear^® or the Nike^® custom shoes. More than likely we feel the CPSIA will require every component to be tested for situations like that.

Custom run screen printers will probably fall into this category, since it's not very practical to send 6 shirts from every order off to be tested (it would add 2 weeks and $320 to the cost of your order - ouch!). In order to comply we have sent samples of each mixed and marketed ink and thread color for testing. We feel that since the garments are still labeled under the manufacturer's label, they do not require testing. However, we are sending them for testing anyway just to be sure. CPSIA is going to decide on the frequency of testing later and we will comply with that rule.

Even if you are the one screen printer that does not carry adult mediums or smaller, why not ensure no lead has sneaked in to your production? It's the best thing for all screen printers to comply with this law. Besides the fact that it's a U.S. Law, it's the right thing to do.

Certification and consumer notification

The CPSIA has a great feature, it requires the manufacturer to provide to the consumer all the testing data so you can be confident that the product has been tested. The data that will be provided to you in the certificate is:

1. Identification of the product covered by this certificate
2. Citation to each CPSC product safety regulation to which the product is being certified
3. Identification of the US importer or domestic manufacturer certifying compliance of the product. (Name, mail, and phone)
4. Contact information for the individual maintaining records of test results (Name, mail, email and phone)
5. Date and place that the product was manufactured (month/year, Name, Address, City, Country)
6. Date and place where the product was tested for compliance with the regulation(s) cited above
7. Identification of the third party laboratory on whose testing the certification depends.

This information can be provided in paper form or electronically. We will provide it electronically by email and also online, so you have access to it anytime you'd like. We will also print the information on your invoice.

Product labeling

Labeling is another important part of the CPSIA changes, perhaps the most useful to the end consumer. All the certifications are useful to the individual receiving the shirts, but once you pass them out, the actual wearer has no clue as to if the law has been followed.

The CPSIA requires all products that require testing to be individually & permanently labeled. The label must contain manufacturer, date of manufacture, and certification information. We have been ahead of this for a while as we have always labeled our products with our manufacturer info. It's very small and integrated into the design. To comply with the CPSIA and provide the most information to the end consumer, we will make the label a custom url that you can look up on our website and get all the information!

We expect to have this lookup URL labeling in effect in advance of the August, 2009 deadline. This page will provide more details on how this feature will function.

Further Research

• "An Act To establish consumer product safety standards and other safety requirements for children's products and to reauthorize and modernize the Consumer Product Safety Commission." Full Text of H.R. 4040 [PDF, opens in new window]