CPSIA: Focus On Apparel Decoration

1. CPSIA: Focus On Apparel Decoration Wednesday, April 18, 2012 Mark Bailey, SanMar Bruce Perryman, MAS, Embroidery Unlimited Anne Lardner-Stone, PPAI

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. Apparel Decoration Required testing on apparel decoration Children’s apparel Child-care articles Assuring ink compliance Tracking labels Exemptions Case studies Best practices

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

5. Required Third-Party Testing For Children’s Apparel • If ink becomes part of the garment 100ppm lead limitin substrate • If ink can be scraped off 90ppm lead limit in paint • Any hard attachments? both lead limits apply to the decoration •  recommended use and abuse testing for small part detachment

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

7. Required Third-Party Testing For Child-Care Items • Lead in paint • Lead in substrate • Lead testing for hard attachments • Recommend use and abuse testing of hard attachments for small part detachment • AND • Phthalate testing

8. Phthalates Ban • Ban on six phthalates in child-care articles: DEHP, DBP, BBP, DINP, DIDP, DnOP • Third-party testing required • Inaccessible component parts are exempt • If found, phthalates likely in decoration or hard attachments such as velcro, vinyl, zippers, buttons, clasps and rhinestones.

9. Paperwork Requirements • All testing must be reflected in Children’s Product Certificate (CPC). • Must be produced and made available for every youth order.

10. Small Batch Manufacturer Exemption • Applies to manufacturers with a reported income <$1 million for calendar year AND have produced <7,500 units of the product in question • Not required to third-party test for: • ASTM Toy Safety Standard • Total lead content in children’s products • Ban on phthalates • Must test for: • Lead in paint • Must ensure that products comply and issue a general certificate of conformity (GCC). • For apparel decoration, must still test “scrapable” ink and hard attachments for lead in paint. • Must register with CPSC as small batch manufacturer.

11. How can you (distributor or decorator) ensure ink compliance?

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

13. Tracking Labels • Required for all children’s products manufactured after 08/14/09 • Enhance recall effectiveness • Required Information: • Manufacturer name • Month/year of manufacture • City/state of manufacture • Batch or internal order number • Distributor PO number

14. 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.

15. 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

16. Secondary Tracking Label • Specifications: • Must be permanent • Hangtags and adhesive labels not acceptable

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

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

19. Case Study 1: Adult-Sized T-Shirt • Required Testing on decoration: • None

20. Case Study 2: Youth-Sized T-Shirt • Required testing on decoration: • Lead in substrate • Lead in paint • Proof of compliance: • Children’s Product Certificate (CPC) • Test reports from third-party lab • Primary tracking label required. • Secondary tracking label may be required.

21. Case Study 3: Infant Bib • Required testing: • Lead in substrate • Lead in paint • Phthalates • Proof of compliance: • Children’s Product Certificate (CPC) • Test reports from third-party lab • Primary tracking label required. • Secondary tracking label may be required.

22. Case Study 4: Infant Sleepwear • Required testing: • Lead in substrate on ink & painted zipper • Lead in paint on ink & painted zipper • Phthalates in “sticky feet,” painted zipper, fasteners and decoration itself. • Proof of compliance: • Children’s Product Certificate (CPC) • Test reports from third-party lab • Primary tracking label required. • Secondary tracking label may be required.

23. 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?

24. 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

25. Best Practices • Maintain records of all compliance documents: • General Conformity Certificate (GCC) • Children’s Product Certificate (CPC) • Third-party test reports • Review PPAI’s How To Read Compliance Documents

26. Resources PPAI: www.ppai.org Product Safety powered by PPAI: www.ppai.org/productsafety Consumer Product Safety Commission (CPSC): www.cpsc.gov PPAI Promotional Products TurboTestTMwww.ppai.org/turbotest PPAI Product Safety Summit: www.ppai.org/summit Questions? AnneL@ppai.org Questions?