Focus On Apparel Decoration

1. Focus On Apparel Decoration Susan DeRagon and Haley Will UL / PPAI Product Safety Consultants

2. This information is being furnished by PPAI for educational and informational purposes only. The Association makes no warranties or representations about specific dates, coverage or application. Consult with appropriate legal counsel about the specific application of the law to your business and products.

3. Agenda • Federal Regulations for Apparel Decoration • Children's Apparel • Child-care Articles • Assuring Ink Compliance • Tracking Labels • Best Practices • Recordkeeping

4. Children’s Apparel Defined • Infant and youth size garments

5. Federal Regulations forChildren’s Apparel CPSIA, Section 101 - Children’s Products Containing Lead • 100 ppm limit • Applicable if the ink becomes part of the garment • Compositing and component testing allowed

6. Federal Regulations forChildren’s Apparel CPSIA, Section 101 - Lead Paint Rule • 90 ppm limit • Applicable if the ink can be scraped off the garment • Composite and component testing allowed • HDXRF or wet chemistry

7. Federal Regulations forChildren’s Apparel Any hard attachments? • Both lead limits apply to the decoration • Use and abuse testing for attachments is recommended (small parts, sharp points, sharp edges)

8. Child-Care Articles Defined • Garment a child three years of age and younger would use for sleeping, feeding, sucking or teething • Bibs • Blanket • Sleepwear

9. Federal Regulations forChild Care Articles • CPSIA, Section 101 - Children’s Products Containing Lead • CPSIA, Section 101 - Lead Paint Rule • Any hard attachments? • Both lead limits apply to decoration • Use and abuse testing for attachments is recommended (small parts, sharp points, sharp edges)

10. Federal Regulations for Child Care Articles • CPSIA, Section 108 – Products Containing Certain Phthalates • 0.1% limit • Permanent Ban: DEHP, DBP, BBP in any amount greater than 0.1 % • Interim Ban: DINP, DIDP, DnOP in any amount greater than 0.1 % • Interim banned phthalates limits apply to toys and child care articles that can be placed in a child’s mouth whereas the permanent ban applies to any toy or child care article • Composite and component testing allowed • Likely to be found in decoration or attachments such as Velcro, vinyl, zippers, buttons, clasps, and rhinestones. • Inaccessible component parts are exempt

11. Mandatory Third Party Testing for Certain Children's Products • Third party testing currently required for: • CPSIA, Section 101 – Children’s Products Containing Lead • CPSIA, Section 101 – Lead Paint Rule • CPSIA, Section 108 – Products Containing Certain Phthalates • Laboratory must be CPSC approved and accredited • Testing frequency prescribed by the Testing and Labeling Pertaining to Product Certification Rule

12. Certification • Importer or Domestic manufacturer is responsible for testing and certification • All testing must be reflected in Children’s Product Certificate (CPC) or General Conformity Certificate (GCC) • Must be produced and made available for every youth order

13. Requirements for Certificates • Identification of the product covered by this Certificate • Citation to each CPSC product safety regulation to which this product is being certified • Identification of the US importer, if applicable, or domestic (US) manufacturer certifying compliance of the product • Contact information for the individual maintaining records of test results • Date and place where this product was manufactured • Date and place where this product was tested for compliance with the regulation(s) cited above • Identification of any third-party laboratory on whose testing the certificate depends

14. Small Batch Manufacturer’s Registry • Small batch manufacturers are defined as those who: • Earned $1 million or less in total gross revenues from sales of all consumer products in the prior calendar year, and • Produced in total no more than 7,500 units of at least one consumer product in the prior calendar year • Registry was launched on December 23, 2011 through the Business Portal of SaferProducts.gov • Qualifying small batch manufacturers are exempted from certain third party tests; however • ALL PRODUCTS MUST COMPLY WITH ALL MANDATORY STANDARDS

15. Assuring Ink Compliance • Have all your inks tested • Rely on ink suppliers’ tests and component testing rule • Perform third-party tests on finished product

16. CPSIA, Section 103 - Tracking Labels • Required for all children’s products manufactured after August 14, 2009 • Enhance recall effectiveness • Required information: • Manufacturer name • Month & year of manufacture • City & state of manufacture • Batch or internal order number • Distributor PO number

17. CPSIA, Section 103 - Tracking Labels • Specifications: • Must be permanent • Hangtags and adhesive labels not acceptable

18. Secondary Tracking Label When a distributor sources from an apparel distributor, contracts with a third-party decorator to apply ink or thread to a garment, and sells the product, the garment has been altered and requires a second tracking label for the same purpose as the first…

19. Secondary Tracking Label • Required Information: • Decorator’s name • Month & year decoration was applied • City & state where decoration was applied • Decorator’s batch or internal order number • Distributor’s PO number

20. Secondary Tracking Label Best Practices • Label Location: • Bottom hemline • Inside back neck • Sewn in as a label behind the original care/tracking label

21. Secondary Tracking Label Best Practices • PPAI Tracking Label Solution • Free to UPIC subscribers • Allows for short URL to satisfy requirements Example: http://ps.ppai.org/SAMPLE01

22. Best Practices • Distributors, ask your buyer… • Who is the intended audience?Will this item be distributed to children? • How will the products be distributed? • What kind of logo do you intend to use? • Do you typically keep items in stock for future use or do you distribute all items? • Do the customer’s preferred products have child-like appeal or playful elements? Or do those products have “diminishing appeal” to the 12 and under crowd?

23. Best Practices • Distributors, tell your supplier and decorator… • The intended audience: • If the item will be given to children • The distribution method • The product you want

24. Recordkeeping • Manufacturer must maintain the following records: • Copy of Children’s Product Certificate for each product • Records of each third party certification test • Separate CPC’s and test records required for each manufacturing site • Records of appropriate periodic tests • Periodic test plan and periodic test results • Production testing plan, production test results, periodic test results • Testing results of tests conducted by ISO 17025 testing lab and periodic test results • Descriptions of all material changes, and the Certification tests related to these changes • Records of undue influence procedures, including training materials and training records/attestations

25. Recordkeeping • Records must be maintained for 5 years, and made available to CPSC upon request • Records may be maintained in languages other than English if they can be provided immediately to CPSC and translated accurately into English by the manufacturer within 48 hours of a request

26. Test Requirements for Common Decorating Methods Applique: Decoration or trimming cut from one piece of fabric and stitched to another to add dimension for design techniques Testing Required:Total Lead Content (may be exempt if untreated textile) Backing: Material used beneath the embroidered fabric to provide stability and support Testing Required:Total Lead Content (may be exempt if untreated textile)

27. Test Requirements for Common Decorating Methods Digital Printing: 4-color process of printing directly from a computer file onto a garment Testing Required: Total Lead in Paint (may be exempt if only CMYK process printing inks are used); Phthalates if childcare article Debossing: A process in which fabrics are engraved with the use of heat rollers under pressure to produce a concave/sunken design on the fabric surface Testing Required: Total Lead Content

28. Test Requirements for Common Decorating Methods Embossing: A process in which fabrics are engraved with the use of heated rollers under pressure to produce a raised design on the fabric surface Testing Required: Total Lead Content Embroidery: Decoration consisting of needlework created using a special machine that is programmed to stitch a design combining texture, pattern and color Testing Required: Total Lead Content (may be exempt if untreated textile)

29. Test Requirements for Common Decorating Methods Flocked Transfer: Very short individual colored fibers are adhered to a transfer sheet to create intricate textured designs that are transferred to a garment using heat Testing Required: Total Lead Content (may be exempt if untreated textile) Heat Transfer: The process of transferring a design from a specially treated paper to a garment using temperatures around 375 degrees F (190 C). Testing Required: Total Lead Content (subject to Lead in Paint, if scrapable); Phthalates would be applicable if scrapable design and item is a childcare article.

30. Test Requirements for Common Decorating Methods Laser Applique: A laser beam is used to cut single or multiple fabric layers revealing a fine, detailed design Testing Required: Total Lead Content (may be exempt if untreated textile fiber) Laser Etching: A process that uses laser technology to etch or burn a mark on a fabric surface Testing Required: Total Lead Content (may be exempt if untreated textile)

31. Test Requirements for Common Decorating Methods Screen Printing: The process of printing by squeezing ink through screens allowing colors to pass through open areas to create a design; Multi-colored designs are achieved using one screen for each color in the design Testing Required: Total Lead in Paint; Some screen printing penetrates fabric such that is not scrapable and then Total Lead Content testing would be applicable; Phthalates if screen printing is scrapable and item is a childcare article Printed Transfer: Printed transfer uses many of the same inks and techniques of printing to create a design that is transferred from a sheet to a garment using heat Testing Required: Total Lead in Paint; Phthalates if childcare article

32. Test Requirements for Common Decorating Methods Sequin Embroidery: A technique in which sequins are embroidered directly onto a substrate Testing Required: Total Lead Content; Total Lead in Paint, if sequins are painted; Phthalates if sequins are painted and item is a childcare article. Specialty Threads: Threads designed for effects such as shine, glitter, iridescence or thickness; The threads are often made from synthetic materials including rayon, mercerized cotton, metallic and textured nylon Testing Required: Total Lead Content

33. Test Requirements for Common Decorating Methods Studded Transfer: Colored metallic and rhinestone studs are arranged on a sheet that is used to transfer the studs to a garment using heat Testing Required: Total Lead Content; Total Lead in Paint, if studs are painted; Phthalates if studs are painted and item is a childcare article. Sublimation: A type of transfer in which dyes, rather than inks, are used to transfer a design onto a substrate with a combination of heat and pressure; The dyes vaporize and are absorbed by polyester fibers; The process can be used to print textiles, as well as mugs, plates, or other specialty items Testing Required: Total Lead Content; Testing may be exempt per below from CPSC website. Certain specialty textile ink systems may use inks that effectively act like dyes. Those inks are absorbed into the fabric and bond with the fabric substrate, effectively acting like a dye.

34. Resources PPAI: www.ppai.org Product Safety powered by PPAI: www.ppai.org/productsafety Consumer Product Safety Commission (CPSC): www.cpsc.gov UL Consumer Products: www.ul.com or Haley.Will@ul.com Questions?: AnneL@ppai.org

35. Questions?