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"The only way to discover the limits of the possible is to go beyond them into the impossible"

~ Anonymous

Tea Time with Liv

CPSIA changes are coming. Are you ready?

First off I am seeing a lot of bad information going around lately and want to encourage everyone to visit their site. You will come across some great people who have read the regulations word for word but in the end you are accepting legal advice from someone without a law degree.

Here is their site http://www.cpsc.gov/about/cpsia/cpsia.html

You MUST get certified with and approved lab. This is stated on their site and they have a listing of approved labs. You cannot get home kits and be compliant. You are not testing all that needs to be tested. Even then in an uncontrolled environment you have results not 100%. I am sure if you read their instructions and fine print this is explained. Get your items tested where they belong.

Here is where you can find approved labs http://www.cpsc.gov/cgi-bin/labapplist.aspx

They are not just testing for lead. The site has tons of information on this and what they are testing for to ensure the safety of products. This seems to be the biggest misunderstanding so I want to remind everyone lead is not the only issue here.

Everyone is so focused on the first set of required limitations but we forget there is more coming. August they are lowered even further if you read the site. This is the beginning of bring down the dangerous limits to ensure safety.

Another that is going around is if the pieces they purchase are certified, no further testing is needed as long as they get certification from their supplier. This is not true. You purchase part A and part B which are compliant and within the listed guidelines but may be over the guidelines when you put them together that creates a new product. Example used often is bows. The barrette is compliant at lead levels of 400ppm, the ribbon is compliant at 300ppm. The legal limit of a finished product as the law stands if 600ppm. Guess what? It is over and it is now a hazardous product. That is why the finished product must be tested.

There are several wanting to share costs. The idea is great but the problem is this is per batch not per product type. The only way this can work is if several of you come together and make 1 product using the same materials from the same batch and sell in one place. Cannot be repackaged in anyway or even modified in any way. Even just a tag change. How do I as the consumer know that the toy fipsy is the same toy wipsy? They can't. Same with the law makers. They can say that yes this is the same exact toy just with a new name and tag based on the company. That is why it has to be tested.

Another I am seeing is the use of the name "assemblers". Many feel if they are assemblers they are not required to test.

What does assemble mean? to put or fit together; put together the parts of:
What does manufacture mean? the making of goods or wares by manual labor or by machinery,

Both put things together to make a specific item correct? So why are they different? They aren't.

It is listed in the law that assemblers, producers, and manufacturer are required to do testing. Just because you are given a different title does not mean you found your loop hole. It is there.

I know it is long, nobody wants to read it, but if you want to save your business and not lose everything over information NOT on the site you must read the law. Don't rely on others to give you the correct information. How do you know they didn't hear it from someone else? What they are saying can they show you in the law where it states what they are saying? This is why you must read it. As a business owner this is your job.

I understand how hard this is. Some just started only to be shut down. I wouldn't want to see my business go through this and I don't want to see others. But with this coming upon us in a few short weeks we need to prepare a plan to keep our doors open. We can fight to the death to change the laws but realistically that may not happen in time. Because of this you may have to close your doors in Feb until you hear whether or not you can open again. That may not happen.

Are you just going to give up? Are you going to risk your business, your family, your home and just illegally? What are your plans to keep the doors open when this goes into effect? Have you received any quotes or just taken the quotes others have posted? If you can't comply what is the next step? You can afford the testing because you received quotes based on your actual product from an approved lab, how will this affect your numbers?

It is time to get prepared. Yes fight if you must but the idea behind fighting to keep a business not to shut it down and just hope things will go your way. You have to be ready to change. Know what you are up against and make it happen.

Make a plan. What do you have that is specifically for anyone under 12? Can you get them from somewhere else that can manufacture enough product where you can buy from them and resell? Can you remove part of your business until you can comply with children items? If you have to close what do you need to do to make that happen now? Remember if you can't comply you can't sell items after the new regulations begin even if you are just selling off your old inventory. Can you close for a short time to reorganize and open in a month or so? If you must close how do you plan to make up the income lost? If you have to remove part of your product line, what will you to do keep your sales steady?

This is planning time not panic time. Think rationally about the future of your business. Emotions have no place here. You want your business? Do something about it instead of waiting for something to happen.


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