Craft & Design

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One handmaker of organic parent/baby accessories, Turtle Park Tots, calculates the true cost the required CPSIA testing on products, going into effect in February:

I’ve telling everyone how expensive the third-party component testing required by the CPSIA is but I don’t think I’ve sat down and actually ran the numbers. Yikes! The costs are truly frightening!

I calculated the costs based on my current Winter Collection and assuming that each component test cost between $75-$100. Not included in these costs are the cost of each test item (they are destroyed in the testing process) and the cost of shipping the items to China since that’s where most of the testing facilities are located.

Materials used in Winter Collection: certified organic cotton fabric, certified organic terry cloth, certified organic cotton fleece, poly thread, velcro, cotton fabric, poly anti-pill fleece, cotton chenille

The numbers: $25325 – $29100 to test the Turtle Park Tots Winter Collection

One commenter pointed out that to meet goals for profits, Turtle Park Tots would have to increase her retail prices astronomically. If you’ll remember, the Consumer Product Safety Improvement Act has the unintended consequence of requiring individual expensive testing of products to make sure they’re free of lead and other hazardous materials before they can be sold in the US. It seems totally unfair that the big companies who created the problems with lead-contaminated toys aren’t the ones who will pay the biggest price, it’s the small independent hand-crafters. How much is the CPSIA going to cost your business? Post it up in the comments. Via Silona’s twitter.

One commenter on BoingBoing debunked the possible loophole of claiming your handmades as “collectibles” instead of toys. Beanoli writes:

The ‘collectible loophole’ would be unlikely to stand up in court. From the FAQ on the Act:

“A “children’s product” means a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, the following factors will be considered:

  • A statement by the manufacturer about the intended use of the product, including a label on the product if such statement is reasonable.
  • Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children 12 years of age or younger.
  • Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
  • The Age Determination Guidelines issued by the Commission staff in September 2002, and any successor to such guidelines.

So any product ‘commonly recognised by consumers’ as a prepubescent child’s toy could be covered by the Act, whether or not it’s labelled as ‘adult use only’, or ‘collectible’.”

More:

Consumer Safety Rules Could Drive Crafters Out of Business

22 thoughts on “Calculating the True Cost of CPSIA Third Party Component Testing

  1. I’m not a crafter BUT! Why are we sending items to be tested to CHINA??????? The country that likes to put lead and other toxins not only in items but in food as well. Would you really trust any results that came from their labs? Forgive me for sounding so horribly politically incorrect but my mind is reeling at this scenario.

  2. Carol, I was just about to post the same thing!
    From a logistical point of view, I can understand having testing facilities in the same country where a large number of products are being made, but if we don’t trust them to not introduce toxins into the items in the first place, do we really want to trust them with testing those items?

  3. There are only 14 labs in the U.S. (if I remember correctly) and I’m sure they are very busy right now. That’s why she’d have to send them to China. Also the tests are cheaper over there. One U.S. lab had an office in Hong Kong; a $50 test in the U.S. cost only $30 in Hong Kong.

  4. How ironic! The CPSIA is mainly because of the lead problems in toys from China, and now that is exactly the place we are all going to have to send our products for testing. Wow! Something is seriously wrong with that. They basically are the reason thousands of small WAHM business are going to be shutting down and now they are going to make a profit off of it.

  5. I haven’t been following this much, but it seems like it would affect and upset a lot of people. Is there anyone, possibly a senator or gov. committee, that is heading up this new law? maybe if their offices can be flooded with enough complaints they might change some things?

  6. Wouldn’t any raw products being used already have been tested? and would they not carry such documentation with them? Am i missing something?

  7. “So any product ‘commonly recognised by consumers’ as a prepubescent child’s toy could be covered by the Act, whether or not it’s labelled as ‘adult use only’, or ‘collectible’.”
    So if I make all my art dolls (which are never intended for children) topless, does this make them NOT ‘commonly recognised by consumer’ as prepubescent child’s toy?

  8. I think I have missed something. I’ve read all the legalese that I could find. If the products: fabric, yarn, batting, etc., have been tested before they could be sold to us, are they saying that the producer, me, is contaminating the final product? I’m now scared to death to put anything out there!! Do they say what the penalty might be? Maybe I’ll just put a tag on the things I sell that say,
    “Not intended for use by persons under the age of 12”.
    Do you think I could get away with that!?! What a big mess.

  9. “How ironic! The CPSIA is mainly because of the lead problems in toys from China, and now that is exactly the place we are all going to have to send our products for testing. Wow! Something is seriously wrong with that.”
    OTOH, some people have the same complaint about having to pay a minimum wage if they want to hire people in the U.S. There are good points against CPSIA, and this is not one of them.
    “I’m not a crafter BUT! Why are we sending items to be tested to CHINA??????? The country that likes to put lead and other toxins not only in items but in food as well.”
    …because the government doesn’t want to stop their manufacturers, including small businesses, from saving so much money by not bothering to keep lead and other toxins out.
    “Would you really trust any results that came from their labs? Forgive me for sounding so horribly politically incorrect but my mind is reeling at this scenario.”
    You’re not politically incorrect, you’re making a very good point.

  10. It’s ironic to see all the ragging about China. It’s a country with a billion people. There are bad things and good things there, just like the U.S.
    Stealth racism towords China is what caused this CPSIA mess to begin with. It’s politically acceptable for both Republicans and Democrats to be anti-Chinese (Democrats because they can rationalize their racism on human rights grounds). The general public also hates the yellow peril, so these factors combined into a rabid “get the gooks” revengefest that ended up in a law that nobody had really thought through, with insufficient public and industry input.

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Becky Stern is a Content Creator at Autodesk/Instructables, and part time faculty at New York’s School of Visual Arts Products of Design grad program. Making and sharing are her two biggest passions, and she's created hundreds of free online DIY tutorials and videos, mostly about technology and its intersection with crafts. Find her @bekathwia on YouTube/Twitter/Instagram.

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