#CPSIA Testing Research for Happy Panda
First we need to find a testing facility and view the list of accredited testing laboratories provided by the cpsia.
- Lead Paint, 16 CFR Part 1303 (effective date 12/21/2008)
- Full-Size Cribs, 16 CFR Part 1508 (effective date 01/20/2009)
- Non Full-Size Cribs, 16 CFR Part 1509 (effective date 01/20/2009)
- Pacifiers, 16 CFR Part 1511 (effective date 01/20/2009)
- Small Parts Rule, 16 CFR Part 1501 (effective date 02/15/2009)
As a clothing manufacturer our clothing line should fall under the lead paint testing deadline because none of these other choices would make sense because we do not create cribs or pacifiers. Happy Panda is a Made in USA brand so we would not choose to send it to a testing facility outside the U.S. We narrowed down the search of the testing facilities and counted 15 accredited labs. I’ve seen postings on blogs that the costs for testing range from $100-$4,000 per test. It’s time to make some phone calls and get a real price range based on our clothing collection. First up!
| Applied Technical Services, Inc. CPSC Identification Number for this Laboratory: 1030 |
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| Address: 1049 Triad Court City: Marietta State/Province: GA Country/Administrative Area: United States Postal Code: 30062 Laboratory Representative: Phil Rogers |
Accreditor: A2LA Accredited: 03/18/2008 Certification: 1888.02 Expiration: 01/31/2010 Scope: Scope Comments (CPSC Acceptance Date): |
Great guy and oh so helpful! I recommend speaking with him if you have questions about testing. He has been testing for several weeks for several companies. He is testing swimwear, shoes, boxes and clothing. Please note he cannot give you any legal advice on how to proceed with your own product, only the testing of your product.
The gray area here is the cpsia’s definition of “reasonable testing.” As a manufacturer it is up to me to issue my own certification that my garments do not have any traces of hazardous materials (lead or phthalates). This can only take place after I have the results from a third party lab. The third party lab does not certify you, they only give you the testing results.
There has been discussions of how third parties are to conduct their testing whether it is the use of the XRF scanner which will be changed to “digestive testing” after August 2009. Phil Rogers is conducting “digestive testing” at his facility.
He and I tried to come up with what I would consider reasonable testing for my own garments. Would it be the fabrics, the different colors, the different sizes, the snaps on our one pieces, the ink that is printed on our garments? The answer? It’s up to me. It’s my responsibility to tell the third party tester what areas to test for! The catch? If I don’t test a particular area because of the cost and hazardous materials are found that is where more trouble than I can imagine would come into play. The following rates are based on “digestive testing” NOT xrf scanning.
What is the rate? For this lab it’s $75.00 per (meaning per area I want to test). For example
Let’s take this Fabulous Snappy outfit and dissect it.
Test 1 snap since the hardware is all the same $75.00
Test the 4 color print (white, pink, purple, turquoise) $75 * 4 = $300.00
Test the 1 color print (white) garment label $75
Test the 2 color print (white and turquoise) $75 * 2 = $150.00
Test the fabric $75
Total Cost: $675.00
I would not test different size because the same components make up the same garment regardless of size. That falls under my idea of “reasonable testing.”
Now let’s talk phthalates! This is taken from the CPSIA’s site -
Three phthalates, DEHP, DBP, and BBP, have been permanently prohibited by Congress in concentration of more than 0.1% in “children’s toys” or “child care articles.” A “children’s toy” means a product intended for a child 12 years of age or younger for use when playing, and a “child care article” means a product that a child 3 and younger would use for sleeping, feeding, sucking or teething.
What is the rate for this test? $300 detects 6 types of phthalates. What is my responsibility? To tell my third party testing lab which areas to test. EACH area that is tested is $300. Do my garments need to be tested for phthalates? YES! Why? because your child could sleep in my garment, your child could put the material of the garment in their mouth! The snappy used in my previous example does not have any materials that would easily go inside the mouth. However, I do carry a gown with sleeves and those would go inside a baby’s mouth.
Now let’s take this gown and dissect it.
Test 1 fabric $75
Test 2 ink on the front $75
Test 3 ink on the garment label $75
Test 4 ink on the back $75
All the inks are the same color. Is it safe to assume it’s all the same ink? No.
Test 5 phthalates on the sleeves $300
Total Cost: $600
Let’s check this one too!
Test 1 fabric $75
Test 2 binding $75
Test 3 velcro $75
Test 4 the 2 colored inks on the front $75 * 2= $150.00
Test 5 ink on the garment label $75
Test 6 phthalates on the bottom portion of the bib $300 (it could be put in a baby’s mouth)
Total Cost: $750.00
I made the decision to post this to show how impossible it will be for me to keep my baby clothing line open. Feel free to do your own math on your own products. This is based on my understanding provided by one set of fees by one third party laboratory. What does this mean? More research!
Call #2 - Bureau Veritas Consumer Products Services, Inc. - I got an answering machine.
Call #3 - Consumer Testing Laboratories, Inc. - Transferred 3 times. In the end I got an answering machine.
Call #4 - Elemental Research, LLC - Spoke to Brian Kiser, he is very nice. The rate? $50 per test. They don’t test metals and they don’t test for phthalates.
Call #5 -
| Environmental Monitoring and Technologies, Inc. (EMT) CPSC Identification Number for this Laboratory: 1050 |
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| Address: 8100 North Austin Ave City: Morton Grove State/Province: Illinois Country/Administrative Area: United States Postal Code: 60053 Laboratory Representative: Jim Cronin |
Accreditor: A2LA Accredited: 11/18/2008 Certification: 2407.01 Expiration: 02/28/2010 Scope: Scope Comments (CPSC Acceptance Date): |
I spoke with Jim Cronin and boy does he know his testing! I can’t really wrap my brain around his rates but they could very well save my inventory. What I can tell you is that there is a $20 lead testing fee and $130 phthalates testing fee and $100 set up. That could be as little as $250 per sample. It’s all based on what your product is and my advice would be to give him a call to discuss your product. These rates change depending on LOTS of variables.
That is all the research that my time allows for today but I will continue to educate myself and I hope that this post will help others further understand the costs of the new regulations.
Thank you,
Pamela Kramer
December 16th, 2008 at 11:11 pm
HOLY COW! It is really espensive…and my research has come up with almost the same numbers…but, I don’t use any buttons on any of my clothing so, there are slightly less testing that needs to be done. Still, no way that this is even possible with the loans I already have out…and I can’t put all these fees on a credit card…it doesn’t make sense…I am just starting to work on my “posh parent” line…for mamas…and jewelry for ages 13 and up! :/ not really my passion but, gotta have a back up plan!
December 17th, 2008 at 2:26 am
Thank you for the posting and please contact me about putting this information on Posh Mama Online Magazine. I want to keep this on the radar of every PM in our community so we can do anything we are able to support you and all of the other members that this would affect. We are behind you 100%.
Much love, xoxo-pm
Posh Mama’s last blog post..Vintage Gifts, Thoughtful and Green!
December 18th, 2008 at 2:35 am
wow, that is so crazy. thanks for sahring Pamela.
Amanda’s last blog post..Wordless Wednesday
December 18th, 2008 at 1:43 pm
I so appreciate posting this information. what a frightening reality check.
this will kill many of us! this regulation is so unreasonable that i almost believe it will be modified. but that would be much too hopeful, wouldn’t it.
December 18th, 2008 at 3:08 pm
HOLY CRAP, I will so have to put this breakdown on my blog to share the knowledge.
LittleLovables’s last blog post..First Birthday, Christmas and Paying it Forward
December 18th, 2008 at 4:22 pm
Very nice breakdown! Its scary to think that this law can go through. I know I am one of many that are keeping ther ears open for news on this.
MadebyMelissa’s last blog post..Save Handmade Toys from the CPSIA
December 19th, 2008 at 12:26 am
I am so grateful to have found your posting. I have been trying to figure out what exactly all these new regulations mean to my company and it’s future. Thank you for taking the time to share what you have learned. I will be linking your post to my blog at woobeemom.com to help inform more small business owners.
December 19th, 2008 at 4:47 pm
That’s just nuts. I posted a summary and link to this on my blog: http://growingnotes.blogspot.com. Thanks for a very informative post!
BellflowerTextiles’s last blog post..Mini Crayons-To-Go Crayon Roll
December 19th, 2008 at 6:08 pm
Thank you so much for your post as well! The more we can spread the word, the more awareness we can create and hopefully, the more letters we can get sent to Congress regarding the unreasonable scope of this Act!
BullfrogsandButterflies’s last blog post..Help Save Handmade Products!
December 24th, 2008 at 12:40 am
Great breakdown. Thank you.
Of course you have to repeat the process every time you get a new batch of clothing blanks…and you really don’t know whether all the snaps on one garment came from the same lot or not….
(OT but may I please say: Big & Tall Babies is an *excellent* idea. Off to explore your site!)
December 24th, 2008 at 12:55 am
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December 26th, 2008 at 1:14 pm
Thank you so much for listing Jim and EMT labs. I’m going to do all my testing with him and he totally walked me through the whole process. Such invaluable information and I so appreciate your generosity and time to put this together. I wish you the best of luck with your line and hopefully we’ll see the law amended to help small businesses while also keeping our children safe.
Best to you!
December 26th, 2008 at 10:45 pm
thank you so much for this information. Talk about sticker shock!
don’t forget that the tests take time. you wouldn’t be able to sell your items until you’ve received the reports from the labs and created your certificates. While it may not take long to test, there will likely be quite a backlog. Who knows how long items may languish in the system, waiting for testing…..*sigh*
kelly
refibered
January 3rd, 2009 at 2:42 am
Thank you for your hard work on this subject. We have checked with a couple of chinese labs to see if the pricing is any less. We were told that it might be cheaper to send our puppets there for testing-I find it interesting that most of the testing labs are in China-where the problems began. We were quoted $1000 to test a small hand puppet with a printed face and yarn hair. We have to test each puppet that uses a different color yarn or fabric and each screen print color. If we change any of the colors in the future the ENTIRE puppet would need to be tested, not the component parts. Redundant testing costs a fortune. The lab we got a quote from (Intek) also “suggested” testing that is not necessary adding to the cost. Since the law is ambiguous and no one wants to interpret it, we are at the mercy of testing labs. I find it very interesting that we will have to send more money to China for product testing since many of the labs in the US have not certified to test for the new standards. Very frustrating for the small business owner.
January 6th, 2009 at 11:09 pm
Thank you for the information. I am a small manufacturer/importer of artisan products made on Peru and Ecuador. My husband has been working with the testing equipment manufacturer about this issue. He has been offered the opportunity to train and perform the xfr tests. After reading your posts I wonder why the labs are so so expensive. Yes, the equipment is very expensive but we were wondering how many small manufacturers we could help if we took the leap and purchased the equipment. My husband was saying he could test products for $5 per test. He would supply the GCC certificates. Keep in mind one t shirt would need potentially 3 tests at a minimum but for $15 it would be reasonable and potentially affordable (fabric, thread, and label). He also thought that at an hourly rate he could probably scan a great number of products. He is not sure exactly how many. I wonder why the equipment manufacturer has never suggested he would not be qualified to perform the test for others. I wonder if anyone knows if the certified list is the only people who can do testing. This is not what we are hearing. I included my email so feel free to contact me. We really feel like we all need to try to get through this. Yes, I too find it ironic that China brought toxins to us and now they reap the benefits. Disturbing.
January 7th, 2009 at 6:12 pm
this information in invaluable!!!! thank you so much.
January 8th, 2009 at 10:04 am
The test cannot be mixed but I know there is a special offer from some labs (of course it is CPSIA accredited lab) in order to lowering supplier’s cost. From my research that price is around $20 for Lead in Paint, $20 for Lead Substrate, $105 for Phthalates (in USD).
Some CPSIA info has been updated to blog: http://textilebulletin.blogspot.com, please kindly visit and comments.
Jupitex’s last blog post..Textile product is related to "Intended to be Released"?
January 9th, 2009 at 4:24 am
Dear Pamela, thanks for your hard work on this. Maybe we can do some help for you!
I’m Jason Kwok, Key sales representative of Toys and Hardline Department from Centre Testing International Corporation.
Center Testing International Corporation(CTI for short) is the first one on the CPSC identification list,CPSC identification number for the Laboratory is 1002 .
As the first approved lab by CPSC of CPSIA ,relying on its professional technicians and advanced equipments ,CTI can provide you impartial date, reasonable charge ,trustworthy ,one-stop testing service your smooth access to the domestic and international market.
May be your tuouble is 3rd-party testing do not provide recommendations and the expensive rate;but our professional engineer may give you valuable suggestions about test ,of course, the right to decide the ultimate test lies in you. And we charge $19 per group for total lead test while $101per group for six species phthalates.
If there is anything I can do for you, please feel free to contact me. Thanks!
My e-mail is: jason.guo@cti-cert.com Tel:86-0755-33681493
Bldg. C, Hongwei Industrial Park, Block 70, Bao’an District, Shenzhen, Guangdong, China, 518101
Website: http://www.cti-cert.com Hotline:400-6788-333
January 12th, 2009 at 5:47 pm
[...] January 12, 2009 at 9:46 PM · Filed under Did you know? #CPSIA Testing Research for Happy Panda [...]
January 12th, 2009 at 11:01 pm
Yep. It’s harsh. I’ve traded emails with a testing lab. No way I can stay in business with this. My I spy security blankets use no fewer than 26 different fabrics and one thread. Plus I don’t usually use the same combination of fabrics twice. My number crunching came up with over 2000 bucks to test them. I can’t do that.
The mind boggles.
Kara’s last blog post..Soft Fabric Animal Picture Book
January 13th, 2009 at 12:17 am
what I want to know, is how I can get an XRF gun and become one of the approved labs…
At least then maybe a bunch of the local craft people could have a “testing and social” evening on a semi-regular basis… or something like that.
trinlay’s last blog post..Cupid flitterbun Bunny
January 13th, 2009 at 10:26 am
Thanks for the numbers crunching. Quite an eye-opener.
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January 13th, 2009 at 12:33 pm
So I just spoke with Gordon at Applied Technical Services, Inc. (the first lab on this blog). He was very helpful! I make baby slings and pouches. He said that yes, each fabric will need to be tested and if there are several colors, then each color needs to be tested. The rate was $75.00 but he said that they can discount that since I have a large quantity that would need to be tested. He encouraged me to first contact my fabric suppliers to see if the fabrics I use have already been tested. I would need certification from them referencing “16 CFR1303″. That is the federal regulation requirement. I also use stainless steel rings and nylon rings. Those would need to be tested. I asked about batches though and he said that unless I change a component (fabric for example) then I only need to have it tested once, not per batch. So, as long as I am using the same rings from the same supplier, then I am required to test once…
He does not test thread. I don’t know if this needs to be done or not…
TAT at this moment for his lab is 10-12 days. He is sending me a submission form in case I wish to use his lab for testing.
Side note: I make my products here in the USA in my living room while my 3 young children are sleeping. I WILL NOT send anything to China to be tested. I am very angry about the amount of labs that are set up in China. I agree-this is very disturbing and completely asinine!!
Great guy!!
January 14th, 2009 at 1:24 am
Jodi Said: “I would need certification from them referencing “16 CFR1303?. That is the federal regulation requirement. ”
Are you sure about that? I had heard that the final product must be tested, even if you have certificates from fabric manufacturers.
There is so much confusion on this… I hear that it doesn’t apply in-state, then I hear it does… urgh… so much for becoming an entrepreneur.
Jen @ Made By Moms’s last blog post..**Bangs head into wall ** Great, my Senator hates handmade….
January 15th, 2009 at 10:49 am
Thank you for posting this information. I am in the same boat looking for laboratories and it was so nice to find that you were willing to post this information.
January 15th, 2009 at 1:15 pm
Pamela, from a link on http://www.harmonart.com, (Harmony is a colleague and friend of ours) I found your Dec 16th post re CPSIA testing. Thank you for such a clear message. I just sent a second letter to my RI senator(see below), Sheldon Whitehouse, with a link to your post. Small business owners cannot affford to meet these new regs. We need our senators to intervene. I just feel that we all have to be ‘part of the solution’. This is my effort today.
Dawn Oliveira
http://www.oliveiratextiles.com
info@oliveiratextiles.com
#CPSIA Testing Research for Happy Panda | Happy Panda Baby
Senator Whitehouse,
I’m glad to hear back from you:
If I can please take a few minutes more of your time; could you, or one of your
staff please read through this December 16th post by business owner Pamela Kramer . It outlines precisely what a small business owner making, in this case, eco-friendly children’s clothing, would need to do in order to meet the new CPSIA mandatory testing regulations. We ALL want to protect our kids from toxic materials; that’s why so many of us in the green movement have been working so hard, over the past many years, to create, eco-friendly products that eliminate these
chemicals from the outset, including having these products tested by third party certifying bodies like GOTS (Global Organic Textile Standards)
Oeko-Tex, Ecocert..and others. The costs of these new tests for every skew on the shelves, will force many small business owners like ‘Happy Panda’,
out of business, at a time when our economy is already suffering tremendously.
There HAVE to be modifications made to this new law.
What can I, and many of my colleagues do, as ‘green’ manufacturers’ to get this point across to Congress?
I look forward to your prompt reply. The clock is ticking.
Kindest regards,
Dawn Oliveira
OLIVEIRA TEXTILES / Sustainable Interior Fabrics
Dawn Oliveira / Founder & Creative Director
info@oliveiratextiles.com
401-396-9194–ph/fax
917-523-3986–cell
http://www.oliveiratextiles.com
In a message dated 1/14/2009 6:29:38 P.M. Eastern Standard Time, sheldon_whitehouse@whitehouse.senate.gov writes:
Contact Sheldon
Constituent Services
Community Dinners
January 17th, 2009 at 10:00 pm
I found a lab in Pennsylvania - Elemental Research. He is charging $50 per pigment - I make knitted (100% wool) stuffed animals. But I cannot afford to have tons of colors tested. I can barely afford to have 5-6 colors tested. Great, every animal in my shop can be brown and tan. :0(
…holding out hope for the natural materials exclusion…..
Sara’s last blog post..Bailey
January 18th, 2009 at 12:59 am
That is just insane and really eye-opening. I had no idea that separate areas had to be tested individually incurring additional cost! Thanks for the post! We’ll keep fighting the fight.
Brenna’s last blog post..Enjoy taking your little ones to the library?
January 19th, 2009 at 5:14 pm
[...] wondering just how costly these tests are, check out this comprehensive article written by Happy Panda. She has done extens ive research on this matter!). It also means that hundreds of thousands of [...]
January 22nd, 2009 at 12:33 am
[...] http://www.happypandababy.com/blog/2008/12/16/cpsia-testing-research-for-happy-panda/ [...]
January 22nd, 2009 at 2:11 am
I have been contacting several testing facilities all in the US. My products are made in a factory in the US. My cotton fabric companies have sent me, or are in the process, stating their fabrics are lead free. I was told I still need a third party testing. I make baby blankets in various colors and sizes. Each color of each pattern must be tested. Nuts. Business is not that great at wholesale to my Specialty stores to spend thousands on these testings. Probably will drop several patterns. Problem is I keep a good size inventory and stock level is high. Can’t sell off inventory after Feb 10 I am a wreck and head into the NY Gift show this weekend.
January 23rd, 2009 at 10:13 am
It really seems like you have gone in deep details to take out the overall cost. I highly appreciate your efforts and thanks for providing this highly useful information. It is certainly a tough criterion to go through all this testing procedure.
January 23rd, 2009 at 2:31 pm
Wow! Thank you so much for blogging about this. This has helped me so much!
January 23rd, 2009 at 4:18 pm
I just saw this link to a women in the Denver area that is trying to put together a Lead Testing COOP here is the link.
http://community.livejournal.com/lj_coop/190899.html?view=6420403#t6420403
January 28th, 2009 at 2:28 am
[...] you’re wanting to see an example of what you may have to pay for CPSIA testing as a child-related product manufacturer, take a peek at this post by Pamela Kramer of Happy Panda [...]
February 9th, 2009 at 7:47 pm
[...] example, Pamela Kramer of Happy Panda Baby offers a fantastic break-down of costs associated with testing her baby clothing line. Her best [...]
May 29th, 2009 at 9:06 pm
Thanks for the info. I have just started making hair bows for little girls and babies (other than my own girls) and was so excited to start doing this from home to make extra money to help make ends meet. This makes me so sad to think that my little “business to be” may not become a reality due to this. I have put my heart into this and I really feel for everyone out there who may be adversely affected by this law. There has to be another way for us to keep kids safe without putting small businesses out of business.
June 28th, 2009 at 8:40 pm
[...] lot of small business owners will be forced to close due to their inability to afford the expensive testing fees which can run from $75 to a hefty $1000! - All depending on the number of material and items used [...]