Calculating the True Cost of CPSIA Third Party Component Testing

Craft & Design


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’.”


Consumer Safety Rules Could Drive Crafters Out of Business

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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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