# How CPSIA will affect fulfillment services?



## scribbleprints (Jan 9, 2008)

I was wondering if anyone has any thoughts on how the CPSIA will affect the various Print On Demand services. There was a post on this on CafePress but it got shut down. (I know there's a general one here too...but I wanted to talk specifically about how it will affect fulfillment services).

I'm guessing that children's product prices may go up next month....and possibly other products since almost any product can have a children's design put on it and marketed to children. Hopefully that's the extent of it.


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## Daniel Slatkin (Jun 25, 2008)

I can only speak for ourselves butt we are removing all junior and baby items from our system we will also be putting disclaimers in all product descriptions explaining that due to the new CPSIA laws that are products are not tested for the use of children 12 and under. I hate to do this to our affiliates butt with the proposed penalties I don't see that I have a choice.


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## Daniel Slatkin (Jun 25, 2008)

WE will also be adding a disclaimer regarding this to our site terms and use of service.


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## Rodney (Nov 3, 2004)

I'll see if I can get some official type info from the various POD places. I think there's a lot of uncertainty at the moment, but it will be interesting to here their take.


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## scribbleprints (Jan 9, 2008)

I found the following on on the FAQ of a product testing site (link: CPSIA FAQ) . Seems like a reliable source since they would have a lot to loose if they steered their customers wrong on this. These two questions I thought pertained:



> *Q7: On a stuffed toy that is produced in one production lot, there is embroidery work done separately on a panel of the stuffed toy that is unique to various retailers. Does the entire toy need to be tested in its finished form, with the unique embroidery thread used for each retailer included in that testing, or can the toy be tested once, and only the various colors of thread be tested on the finished product?*
> 
> A7: The finished product needs to be tested, rather than the components prior to assembly. However, once you have tested that component on the first finished product, you should not need to test it again and again but rather can refer to the previous testing. So it's not component testing but rather finished product testing that avoids duplicate testing of same materials or components.
> 
> ...





So, if this is correct, it seems if a POD did one product printed with squares of all of the inks used, and tested those squares on that finished product, as well as all parts of the product itself (snaps, material, tagetc.) then they could refer back to that to show compliance. At least that's how I read that.


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## jeggers (Nov 22, 2006)

Hi, all,

From the Spreadshirt side, first, this type of legislation supports our core values as a company. We want to be in compliance with something like this, because it is the right thing to do.

How we will handle it is that we ask our vendors to verify and give us certification. This type of regulation will be added to our standard compliance letter we have for vendors. We do have some vendors that do not sign. This is either due to them having their own code of conduct that they refer us to, or them feeling they cannot reliably trace the source of every item they purchase. At that point, we have a decision to make as to whether their product is the one we need. With children's products this decision point would be stricter in this case.

So overall, this legislation doesn't concern us such that we would remove Children's products, we will be putting a higher bar on our vendors.

We are working on a page that fully discloses all of our vendors, manufacturing locations for what we purchase, certifications provided, etc. We would add this to that information.

Hope that helps!
Jana


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## Daniel Slatkin (Jun 25, 2008)

scribbleprints said:


> I found the following on on the FAQ of a product testing site (link: CPSIA FAQ) . Seems like a reliable source since they would have a lot to loose if they steered their customers wrong on this. These two questions I thought pertained:
> 
> 
> 
> ...


The way this was explained to me we would have to test for each individual new Design we printed on a product, we would then be Ok to sell that exact product, but any changes in design, color, print size, new ink batch etc.. would need to be tested. 

By the nature of print on demand each new print is a single item in a unique product manufacturing run therefore needs to be tested and labeled as so.

I am not a Lawyer and I strongly recommend that if you are in doubt as to weather you comply with this new law to seek Legal advice a small fee now is way better than a huge fine latter, and possibly jail time.

This is how the attorney I had look at it interpreted it. He advised us to not print children's or junior Items until this law sorts itself out. He said our best and safest course of action was to wait and see what happens, write our congressmen and inform and get as many involved as possible.

The devastating effect of this law on the Economy as a whole will devastate a lot of people unless something is done to change it. It will be impossible for the small domestic manufacturers of goods to compete so therefore they will either have to close or move their manufacturing out of country to make up for the new added testing cost.

This law will cause all the small cottage industries in America that cater to children 12 and under to go out of business. It will effect the costs of so many things it is hard to fathom. I am all for protecting children butt this law lacks all common sense.

I have contacted so many people who will be directly effected by this that have no clue. It will be a very interesting to see how they go about implementing this law, and enforcing it. Butt I was told and have read in several places that they plan to start with online first because all they have to do is send an E-mail and ask for your testing proof.


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## Daniel Slatkin (Jun 25, 2008)

According to the law it does not matter that all of your supplies are tested and certified, it's the final product that they are worried about. It's the final product that needs tested, this is the part of the law that lacks all and any common sense.


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## jeggers (Nov 22, 2006)

Hi, Daniel,

I am not giving anyone legal advice. I am telling you how we see it and will act ourselves.

From our perspective, there is a differentiation between manufacturers and resellers in the legislation. Specifically, there is not a clear line when you enhance a product, as to how you will be considered. If we have certification that lead is not introduced by our vendors for each step in the process (which does not just include physical pieces we put together, but also the environment in which it is done), we feel comfortable with our decision. This does not mean anyone else has to. For our shop partners, they are free to decide what makes them comfortable and they can include what they want to include in their selection.

Thanks,
Jana


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## perrolocodesigns (Oct 24, 2006)

Good article at Bloomberg.com on the CPSIA

Bloomberg.com: News


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## Heidi (Sep 13, 2006)

The DAX (Decorated Apparel eXpo) is going to have a speaker from SGIA discuss this very topic in Kansas City and Minneapolis. I don't know if it's listed on their website yet but here is the link: The Decorated Apparel Expo - Embroidery Trade show convention and screen printing trade show convention for Embroiderers and Screen Printers


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## scribbleprints (Jan 9, 2008)

Heidi said:


> The DAX (Decorated Apparel eXpo) is going to have a speaker from SGIA discuss this very topic in Kansas City and Minneapolis. I don't know if it's listed on their website yet but here is the link: The Decorated Apparel Expo - Embroidery Trade show convention and screen printing trade show convention for Embroiderers and Screen Printers



Thanks Heidi! I looked on the site, and it looks like this is free to go to (since it's free to go to the Expo if your pre-register...and only $5 if you don't). Is that correct? I'm not near those cities but will pass on the word on my blog.


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## Heidi (Sep 13, 2006)

Yes Gale, that is correct...it's $5 at the door if you didn't pre-register. I talked with Scott Ritter who is the owner of DAX, Inc. He said, 
"Marci from the SGIA completely changed her topic to discuss CPSIA in Kansas 
City. Admittedly, there is no person in the industry better suited to 
answer any questions you have on this topic than Marci or Katy. They are 
both in the Washington DC area continuously covering legislation and 
lobbying for our industry."


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