 Thank you so much for joining us. I am really excited to talk to you about bibs verb class and blankets I I do have to give the disclaimer that we give at the beginning of all of our presentations Which is that this presentation was prepared by cpsc staff specifically the small business ombudsman team and the Presentation today may not necessarily reflect the views of the commission So our agenda today. I'm going to start off by talking about children's product requirements These are requirements that apply to all children's products and we define a children's product to be an item That is meant for a child ages 12 and under And just to clarify you see there's an asterisk next to the agenda The webinar today is going to focus on blankets, but these are not wearable blankets. So we're not going to be covering Adult wearable blankets that might have zippers that are meant to be worn almost like a onesie for an adult We're also not going to cover wearable blankets for children something akin to like a sleep sack But as we get more in depth in the product categories, I will make those points clear So in addition to talking about everything that applies to children's products because bibs verb cloths and kids blankets Are children's products? I'm also going to talk in more granular detail about the testing requirements that apply We get a lot of questions about you know the difference between total leg content and lead in paint So I'll explain those types of Differences to you guys and we'll go through each of the testing requirements that could apply To bibs verb cloths and blankets and I'm also going to do what I hope is fun Which is an interactive audience? polling Section where I'm going to ask you questions after we've covered content to see whether or not You've understood I guess the message that we're trying to convey And hopefully you find that a fun interactive part of today's presentation After going through the testing requirements product by product Then I'll talk about small batch manufacturer registration benefits including what it means to be a registered small batch manufacturer and how you qualify Then I'll go through how to find a cpsc accepted testing lab And how frequently you need to test I'll talk about children's product certificates and we'll actually look through three example children's product certificates one for a bib One for a verb cloth and one for a blanket and again. These are hypothetical products We're using you know stock photos here in the presentation To help us give you examples of how to make a children's product certificate for this product category or these product categories And then I'll highlight a few recall examples and bibs verb cloths and blankets Things that have been either a defect or A regulated issue on these products that have necessitated a product recall Just to help you design and make and import safer products in the future I'll highlight some cpsc business resources And then we'll have a q&a session at the end But again, you are welcome to ask questions throughout the presentation today Using the question section on the right hand side All right, so first let's talk about Requirements that apply to All of bibs verb cloths and blankets for kids These are children's product requirements The first is the tracking label requirement or permanent tracking information And tracking labels need to be permanently affixed to both the children's product and its packaging It needs to provide identifying information Specifically, we're looking for manufacturer or private labeler name Location and date of production of the product Detailed information on the manufacturing process such as batch or run number And any other info to ascertain the source of the product And usually in that case for the fourth bulleted item We say something like a web address if your company has a website We do have a lot of helpful frequently asked questions related to tracking labels And those are available via our tracking label FAQs page Which shows on my screen as a hyperlink But again, you'll need to download the handout in order to be able to follow the hyperlink embedded in the pdf All children's products also require a children's product certificate Which i'll talk about in more detail later in the presentation So if you are making bibs or burp cloths, those are children's products They definitely require a children's product certificate if you're making blankets for kids Meaning they're intended for children 12 and under they also require a children's product certificate And a children's product certificate. We also call a cpc There are seven pieces of information that go into it We'll talk about what those are and we'll go through some examples But this is another category that we receive a lot of questions on So we do have helpful frequently asked questions available on our children's product certificate page Which again is hyperlinked on the screen and in your downloadable handout All right, let's talk about the testing requirements themselves And we're going to start with the chemical ones and then we'll move on to the non chemical more physical and mechanical testing requirements The first one Lead content is also called substrate lead. Sometimes we see that reference to substrate lead applies to all children's products in accessible components The limit there is 100 parts per million and this requirement actually comes from congress 15 usc 12 78 a is the citation there We'll talk more In detail and later slides on each of these requirements and whether there are testing exceptions exemptions Or material determinations that could mean you don't need to test But for now, let's just remember that leg content is is the same as substrate lead and has a 100 parts per million limit And applies to all children's products For lead and paint and surface coatings. This is a different type of lead testing That is applicable to components that contain paint or surface coatings And the way you know whether lead and paint or surface coating Limit of 90 parts per million applies is whether the coating or paint could be scraped off the surface with a razor blade Sublimated or similar coatings and dyed colorants are not subject to these requirements And that's per our regulation 16 cfr 1500.91 And that's a whole list of material determinations there that includes cmyk inks Which fully absorb into a substance and don't sit on the surface So if you have a paint or a surface coating that sits on the surface And you were to scrape the surface with a razor blade And it would come off it would be subject to lead and paint and surface coatings testing at 90 parts per million There being the limit The next type of chemical testing is phthalates testing Phthalates are plasticizers. They make things pliable Often we use the example of a rubber duck as something that has a lot of phthalates in it because it's very pliable You can squeeze it and it gives There is a limit of 0.1 for each band phthalate and there are eight We'll talk about those in more detail But the phthalates testing requirement comes from our regulation 16 cfr part 1307 Phthalates apply phthalates testing applies sorry to all plasticized components and toys and child care articles Child care articles are products for children under three that facilitate sleeping eating sucking or teething And again as we move through bibs for blossom blankets We will break down in more granular detail whether phthalates testing would apply to them So we've talked about the chemical testing. Let's move on to the physical and mechanical testing Small parts testing small parts are banned in products for children under three This testing requirement comes from our regulation 16 cfr part 1501 However, children's clothing is exempt And that comes from our regulation 1501 point three We'll talk in more detail about what that means as it applies to bibs for blossom blankets in just a bit And the last testing in this overview that I just like to bring to your attention Is apparel flammability standards at our regulation 16 cfr part 16 10 and 16 11 16 10 is for wearing apparel And 16 11 is for vinyl plastic film And again, we're going to talk product by product as to how this may apply to them No, sorry. All right. Let's talk about leg content in more granular detail So this was the first testing requirement that I just showed in the testing overview This is a requirement from 15 usc 12 78 a so this is a congressional statute The limit again is 100 parts per million in accessible parts of a children's product However, I referenced earlier that our agency has passed a regulation 1500 point 91 That lists certain materials or substrates that would not be subject to leg content testing And those are all listed in 1500 point 91, which is hyperlinked in your handout, but we've highlighted a few here So I talked about earlier cm yk process printing inks being one example Those are inks that fully absorb into the substrate. Those would not require leg content testing Natural fibers dyed or undyed including but not limited to cotton linen hemp bamboo Cisal silk and sheep wool In addition to manufactured fibers both dyed and undyed Including but not limited to rayon liacel acetate triacetate rubber polyester nylon acrylic moda acrylic and spandex Velcro and aplex would also be considered textiles under the 1500 point 91 determination They would also not require total leg content testing And I just wanted to highlight here. There are other materials that are listed in 1500 point 91 That are not traditional fabrics things like certain types of stainless steel shells corals certainly not certain naturally occurring Substrates are also listed in 1500 point 91 So if you are making a children's product be it bibs burp cloths and blankets for kids or Other children's products meant for kids under 12 take a look at that list of materials because total leg content or lead substrate lead testing is going to apply to you and you know the more you can make your children's product out of the materials determination Contents the better in terms of testing for you So of note here zippers snaps and other fasteners that are made of many metal or poly resin must comply with the total leg content limit because metal or poly resin Even plastic, you know a lot of those are made of plastic Are not going to have materials determination in 1500 point 91 that would cover them. So they would need lead content testing Additionally polyurethane laminate or pole Would not need testing if it's inaccessible So leg content testing applies to accessible component parts if you have pole in your product But it is in between two layers of fabric Potentially manufactured fibers may be two layers of polyester Say if the pole is not accessible it would not require leg content testing and that has to do with accessibility Not to do with the determinations of 1500 point 91 All right, let's talk about lead in paint Again, this is a a testing requirement that comes from our regulation 1303 The limit in paint and surface coatings is 90 parts per million We just went through in total leg content all the testing material determinations that we have made And put out there meaning if you make the product out of those Materials you don't need to have lead testing or lead substrate testing conducted There is no equivalent for lead in paint and surface coating. So there are no exceptions or exemptions to this testing requirement So the main thing to remember here is children's products with a surface coating Meaning a surface applied to a substrate that does not absorb into the substrate That's that razor blade test again must meet the lead in paint requirements The way we generally see this in our office in terms of questions and on products Is screen printed fabrics? A lot of screen printed fabrics require testing for lead in paint and surface coatings Additionally painted zippers buttons or snaps would need testing for both total leg content Because they are you know potentially made of metal or poly resin or plastic So the total leg content testing needs to be done on the zipper or snap substrate itself the material that it's made of And you would need testing if it's painted for lead in paint They would need to scrape off the coating or the paint and do lead and paint testing because again those There's two different limits. They're 100 parts per million and 90 parts per million on substrate versus coatings That would need to be done All right, that late's testing again. These are the plasticizers the rubber duck example that I used Uh, this comes from our regulation 1307 The limit is 0.1 Per band phthalate. This applies to plasticized components. So we're talking about snaps buttons or certain screen printing inks Phthalates testing applies to toys and child care articles And again child care articles are products for kids under three that facilitate sleeping Eating sucking or teething and we'll talk about what that means product by product a little bit later For phthalates the good news is is that our agency has made determinations here for two different categories of materials the first is Uh, children's toys or child care articles that are made with seven plastics that contain specified additives The plastics are shown on your screen, but they are polypropylene polyethylene high impact polystyrene Acrylonitrile butadiene styrene general purpose polystyrene medium impact polystyrene and super high impact polystyrene and we've got the abbreviations for each of the seven plastics after each of the names This list is explained in more detail at our regulation 16 cfr 1308.2 Which is hyperlinked again in your handout The other category Of materials that you could make a child care article or a toy out of that would normally be subject to phthalates testing But would not require phthalates testing would be using unfinished manufactured fibers that are untreated and unadulterated If you are using polyester or peat nylon polyurethane or spandex Biscoe rayon acrylic and moda acrylic or natural rubber latex Then you would not need to conduct phthalates testing If you're making a toy or a child care article and again We'll talk product by product on bibs burp gloss and blankets for kids and the different Manifestations we've seen or I guess I should call them ingenious inventions That have add-ons for each of those categories and whether or not this applies and whether the determinations For phthalates would also apply but again the unfinished manufactured fibers materials determinations Are listed at 16 cfr 12 53.2 c and that's available via hyperlink in your handout All right, so we've come to the first Of three poll questions. So let's see how you guys do our first poll question It's going to be about phthalates and it is a true or false question The question is all bibs burp cloths and blankets Must be tested for phthalates So i'm going to put the question up on your screen And you should have the ability to click Either true or false and I see answers are coming in Thank you everybody for doing this Oh, one answer is definitely taking the lead. I'm going to give Folks just a few more seconds to get their answers in All right, I'm going to close the poll and let's see what we thought The answer to this question was so It looks like most folks thought the answer was false on whether bibs burp cloths and blankets all of them must be tested for phthalates Let's see if you guys were Correct You were correct the majority of you I think 86 percent were absolutely correct. The answer is false We can't make a blanket statement here. Um, not to make a blank blanket fun But we cannot make a blanket statement for all bibs burp cloths and blankets being Testive for phthalates because only child care articles that are intended for children under three that facilitate sleeping eating sucking or teething And contain plasticized component materials need to meet phthalates testing So what does this actually mean in the real world? It means all bibs meet this definition and therefore would be subject to phthalates testing And again, I talked about those materials determinations that unfinished manufactured fibers And the seven specified plastics or the seven plastics was specified additives We'll talk about those in a little bit more detail in the bibs section But bibs are going to need phthalates testing They would be subject to it and it just depends on whether you're making your bib out of a material It has a determination that means phthalates testing does not apply if you are not You would need to have phthalates testing conducted Burp cloths are typically not going to need phthalates testing because they are not a child care article Even though burp cloths are used to when a child spits up They are not part of the process of feeding a child. So we do not in general consider them a child care article In their traditional, you know, a standard fabric only burp cloth that's meant to catch a child spit up Baby blankets including swaddle blankets may require phthalates testing And this is going to depend on their composition their design and their marketing If the blankets are meant to facilitate sleeping eating sucking or teething So we have seen blankets that contain a teeter. We've seen blankets that contain a toy We've seen blankets that are baby blankets that are meant clearly for a child under the age of three to sleep with Then in those cases phthalates testing would apply if it is a blanket that Is a kid's blanket because of the design that's on it But it's not meant specifically for babies. It's not meant to swaddle a baby in But it, you know, it's meant to be thrown on a chair in a child's room and that child is, you know, in middle school That would not be a child care article and it would not be subject to phthalates testing Just based on that hypothetical example All right, so let's talk about Small parts you guys knocked it out of the park with the chemical testing Audience poll. So let's see how we do on the physical and mechanical tests For small parts this comes from our regulation 1501 The purpose of this regulation is to prevent deaths and injuries to children from choking Small parts are banned in products for children under the age of three However, and I mentioned this earlier In our regulation 1501.3 again hyperlinked in your downloadable handout Children's clothing which would include fabric bibs as wearing apparel are exempt from small parts testing So with that in mind Let's do our next audience poll And the question here is true or false All bibs burplocks and blankets must be tested for small parts So I'm going to launch this question and let's see how we do on it We have some very quick studies here. I can tell All right, I see most folks have answered I'm going to give you just a few more seconds to get your answers in All right, I'm going to close the poll and let's see what we thought the answer was on whether all bibs burplocks and blankets Must be tested for small parts It looks like we are split almost exactly like we were in the previous poll on phthalates testing here for small parts 85 percent are saying false 15 percent are saying true all bibs burplocks and blankets must be tested for small parts So let's see what the right answer is The answer here is again false Items of wearing apparel such as bibs are exempt from small parts testing under our regulation 1501.3 d So bibs or sorry blankets and burplocks Intended for children under three that contain buttons snaps grommets or other fasteners Would likely need small parts testing So answer here was false 85 percent of you were absolutely correct The one thing that I do want to note and it's a question that we get quite commonly Is that burplocks and blankets made solely of soft fabric? Do not present a choking hazard and need not undergo small parts testing So even though they are not themselves considered apparel The fabric itself is not going to present a choking hazard and and therefore we're not going to be looking for small parts testing on Fabric only burplocks and blankets So let's move to the next physical and mechanical test And this is actually the last one that we have to talk about today before we get in more in depth on the products Which is flammability testing and there are two types of flammability tests that we'll be talking about today I will reference sleepwear ones a little bit later, but it's It's kind of outside the realm of today's presentation The two flammability tests that we should focus on are 1610 and 1611 1610 is for wearing apparel and 1611 is for vinyl plastic film So flammability testing is applicable to fabric or material for use in adult and children's wearing apparel So this is a yes for fabric bibs bibs are meant to be worn. They are an item of apparel They are subject to flammability testing Flammability testing does not apply to burplocks or other blankets that are not meant to be worn as clothing Good news with flammability testing just like lead content and phthalates We do have a in small parts. Actually, we do have a list of exemptions at 1610.1 D hyperlinked in your handout for two categories of fabrics The first is plain surface fabrics that weigh more than Well equal to or more than 88.2 grams per square meter Or 2.6 ounces per square yard if you like the english units And that is regardless of the fiber content. So it doesn't matter what the plain surface fabric is That's the Exemption there and then plain and raised surface Fabrics regardless of weight made entirely of acrylic motor acrylic Nylon olefin polyester wool or any combination of these fibers would also be exempt from flammability testing All right, so let's do the last audience poll question And I have a feeling you know what it is, which is All bibs burplocks and blankets must be tested for flammability I'm going to give you guys just a minute to get your answers in. Oh, wow. People are voting very quickly Almost all of you have voted. So I'm going to go ahead and close Out the poll. Let's see what we thought the answer was on this question Resoundingly you thought the answer was false that not all bibs burplocks or blankets need to be tested for flammability That was 96 of you. Let's see what the right answer is You guys were correct 96 of you guessed correctly The answer is false only items of wearing apparel such as bibs and fabric material for use in wearing apparel must meet flammability requirements Burplocks and blankets that are not meant to be worn as clothing are not considered wearing apparel And therefore do not need to meet flammability requirements So in the case of blankets not meant to be worn as clothing We are specifically talking about excluding things like sleep sacks for children and adult 1z wearable blankets that might have a zipper or snaps or something All right, so let's talk product by product for bibs We've broken this into bibs that are made of fabric and bibs that are made of silicone The first one is bibs made of fabric You've got an example product in the picture of the little cutie wearing her Fabric bib in the top right The four tests that are potentially applicable there are total leg content However, we're keeping in mind that there are all those material determinations That would not require lead content testing if you make the bib out of those fabrics lead in paint and surface coatings and we've put if applicable there because This only applies if you have paint or a surface coating on the fabric bib Phthalates testing again, I've put if applicable here because remember we have that list of determinations for unfinished Manufactured fibers or untreated manufactured fibers that would not require phthalates testing And then apparel flammability standards The two standards for wearing apparel at 1610 and vinyl plastic film at 1611 Again, I've put if applicable because remember there are the two testing exemptions for flammability based on fabric weight Or the fabric plain surface fabric weight or the fabric that it's made of specifically the seven fabrics that we just went through an earlier slide So for silicone bibs the required testing is actually the same however The materials determinations are applied differently because the material is different. So for total leg content Silicone does not fall under any of the determinations from 1500.91 like a traditional fabric like polyester or cottonwood So you a silicone bib would need to be tested for total leg content and again the limit there is 100 parts per million Lead in paint and surface coatings could apply here I have if applicable because again only applies if there is paint or surface coating on the silicone bib And that could even be keep in mind if you have a snap and the snap is painted or has a surface coating on it But the silicone bib itself does not it's just that one component part That one component part would need lead in paint and surface coatings testing on the paint or surface coating on that snap phthalates testing Again with the fabric bibs. I talked about phthalates testing having potential Untreated or unfinished manufactured fibers as a materials determination meaning you wouldn't have to do phthalates testing potentially Silicone is not in the list of the seven specified plastics with or seven plastics with specified additives So phthalates testing would need to be done on a silicone bib for flammability Again a little different than with the fabric bib the flammability standards for 16 10 or 16 11 do apply but The weight of silicone exceeds 88.2 grams per square meter or 2.6 ounces per square yard Therefore testing is not needed for 16 10.1 d So let's move on to burp cloths Burp cloths that are 100 fabric The required testing is total leg content Again, this is the 100 parts per million limit But keep in mind those material determinations, which are pretty extensive and include manufactured and natural fibers Lead in paint and surface coatings Just like in bibs that we were just looking at would only apply if there's a surface coating or lead on or sorry or paint on the burp cloth itself The reality for most 100 fabric burp burp cloths is that there is likely no applicable testing That are made of 100 fabric Now that does not mean that you don't still need to comply with the tracking label requirements That we talked about at the beginning of today's presentation And it doesn't mean that you don't need to comply with the children's product certificate requirements You do still need to meet tracking label and children's product certificate requirements And we'll talk about the certificate in just a little bit. Uh, just a few more slides So burp cloths that contain Non-fabric adornments such as a snap a button or paint would be subject to total leg content and accessible components And this is specific to the non-fabric Adornments so the snaps the buttons those would be subject to lead substrate or total leg content testing If there is lead and paint and surface coat or lead and paint and surface coatings would apply If there is paint or surface coatings on this fabric burp cloth that has a snap or a button on it and uh, again, you want to think of your product as a One big piece that contains multiple components If all you have is one painted snap that painted snap Would be subject to leg content testing and lead and paint testing for the paint or surface coating that sits on the snap Small parts testing could potentially apply to fabric burp cloths that contain non-fabric adornments such as snaps Buttons or paint depending on their design and how they're advertised and marketed for blankets The great news is if you make adult or general use blankets meaning a blanket that is not specifically designed intended or marketed For children 12 and under and that would be a general use blanket There is no required testing nor is there a tracking label requirement and no certificate Either a children's product certificate or a general certificate of conformity or a gcc No certificates required For children's blankets These are blankets that are meant for kids 12 and under and are advertised as such that are made of plain 100 fabric Lead content testing would apply. However, keep in mind. We've got that long list of materials determinations for fabrics phthalates testing Could also potentially apply if the 100 percent children's blanket fabric children's blanket is intended for use by children under three But keep in mind on the phthalates testing. We have the two determination Uh materials determination categories one for unfinished manufactured fibers, which you may fall under and means that you could Not have to do phthalates testing or seven plastics with specified additives If you have a non fabric adornment or something on a children's blanket That is also a potential Item that would not be subject to phthalates testing For a fabric children's blanket with non fabric adornments such as snaps buttons or paint you're subject to lead content Specifically here. We're looking at lead testing for fasteners or other non fabric adornments And lead in paint or surface coatings testing again on those non fabric adornments the snaps buttons or Any screen printing that might be on the product lead in paint and surface coatings would apply there But if you don't have surface coatings or paint on any part of your fabric children's blanket lead in paint and surface coatings testing would not apply phthalates testing again just like the example above Would apply if the children's blanket is intended for use by a child under three However, we've got those two material determination categories for unfinished manufactured fibers and seven plastics with specified additives That might remove you from phthalates testing In those product categories Small parts would also apply here Because this is not a children's clothing item And again, I should have said this when I came to this slide We are talking about non wearable blankets here. So non wearable adult onesies and non wearable Blankets for kids so not sleep sacks this those have different requirements that apply to them Other than what is shown on your screen. So that's outside the scope of today's presentation All right, let's talk about swaddle blankets and we've got an example of a swaddle blanket on the top right of your screen The disclaimer here is that swaddle blankets could be subject to 16 cfr part 16 10 which is flammability for wearing apparel or 16 15 or 16 16 which are the two children's sleepwear flammability requirements Depending on how they are designed and marketed For purposes of today's presentation, we are talking about swaddle blankets that look like the one in the picture on this Slide that are just fabric and may contain a fastener or a painted surface. They are not meant to be worn they are used to Constrain the movement of a young child So a plain 100 fabric swaddle blanket would be subject to lead content Again materials determinations there could mean that you do not need to do lead testing Lead in paint and surface coatings again just like before is only going to apply if you have Something like a screen printing on your fabric swaddle blanket That would subject you to paint and lead in paint and surface coatings testing if you don't have that it would not apply Phthalates testing would also apply because swaddle blankets are meant for children under the age of three to facilitate sleeping However, keep in mind. We've got the determinations for unfinished and unadulterated Manufactured fibers that you could fall under which would mean that you don't need to do phthalates testing there For fabric swaddle blankets that contain fasteners or painted surfaces lead content is going to apply And would likely only be applicable to the fasteners Lead in paint and surface coatings could potentially apply again if the fastener or painted surface Meets the definition of a paint or a surface coating that would lead in paint tests would apply Phthalates testing would apply just like with the regular 100 fabric swaddle blankets However, two categories of determinations there are manufactured fibers and seven plastics that could mean you don't need to do phthalates testing And lastly small parts testing would apply here because this isn't just an all fabric item And swaddle blankets are not items of children's clothing. So they are not exempted from small parts testing So it would apply to a fabric swaddle blanket with a fastener or painted surface So what about a blanket or a stuffed animal combo such as the one shown On the right hand side of your screen? I I do it meant for it to be considered a blanket It would probably need to be a little bit bigger than what is shown on your screen because relative to the hand It looks quite small but imagine that as a little bit of a bigger blanket with that cute elephant As a stuffed or a crocheted toy that's attached to it If you are making or importing blankets that are have a stuffed animal combo Then that item needs to meet both the children's blankets requirements, which we've discussed And the stuffed toys requirements The good news here is that we have done a webinar specific to stuffed toys that actually walks you through testing for stuffed toys And that webinar is hyperlinked In your downloadable handout, it's also available on our cpsc youtube business education playlist The thing to keep in mind is that when we made that webinar, uh, the toy standard version was different than it is currently So, um, it's going to be referencing an older version of the toy standard the toy standard that you need to meet Toy standard version you need to meet now is astm f 963 dash 17 All right, so for those of you that like charts I've turned what was Slides and slides of content into Four pages of charts so that it is easier Potentially for you to see the distinctions in different product categories So for bibs made of fabric and silicone They are going to be subject to total leg content testing But the ones that are made of fabric Are likely not going to need testing because they fall under those material determinations Lead in paint and surface coatings doesn't have any testing exemptions or exceptions or material determinations So any bib that contains paint like a screen print That sits on the surface and would scrape off with a razor blade Or contains a surface coating that would also scrape off with a razor blade subject to lead in paint testing For phthalates testing bibs facilitate eating for children under the age of three So they are subject to phthalates testing For the ones made of fabric keep in mind. We've got that materials determination For unfinished manufactured fibers for the ones made of silicone Keep in mind. We've got the seven plastics with specified additives The likelihood there though is you're not going to fall under those seven plastics with specified additives If the bib is actually made of silicone because the seven plastics do not contain silicone, but They're you know depending on the category you could fall under it. So it's worth looking into for Bibs they are subject to flammability because they are items of wearing apparel For those that are completely made of fabric Remember, we've got the materials determinations based on material weight and or content. That's the seven um fabrics that it can be made entirely of that wouldn't subject it to flammability testing for silicone bibs also subject to flammability testing all bibs are But likely no testing because silicone is going to exceed that plain surface material weight of 88.2 grams per square meter For small parts testing bibs are items of clothing. So they are exempt under 1501.3 for burk cloths ones that are fabric only And those that contain snaps or buttons They're going to be subject to total leg content The fabric only ones are likely going to fall completely under those material determinations at 1500.91 For the snaps and buttons the fabric portions are going to fall under material determinations at 1500.91 But snaps and buttons would require testing for total leg content at that 100 ppm limit Lead and paint and surface coatings again only applies if that is on the burk cloth itself Valates testing would not apply because burk cloths are not considered a child care article by the CPSC and that's the Valates testing applies only to children's toys and child care articles Flammability testing would also not apply to burk cloths because they are not items of wearing apparel and uh small parts testing would not apply to fabric only because Fabric itself does not pose a choking hazard But if it contains snaps or buttons a burk cloth is not an item of clothing or children's clothing So it would not be exempt from small part testing. So it would be subject to small parts testing For blankets adult blankets across the board no requirements. Again, we're excluding wearable blankets For adults, but non wearable blankets That aren't meant for kids. No requirements Children's blankets or swaddle blankets again. These are not the wearable sleep sack type blankets For kids are subject to total leg content The fabric is not likely going to need less testing based on the material determinations and the snaps buttons and other pieces would Lead and paint and surface coatings again only applies if there's paint or surface coatings for phthalates testing This is you know, it's a close call. It depends on the product design If the product is meant for a child under three like a swaddle blanket Then phthalates testing likely applies. However, we've got those two materials determinations for unfinished manufactured fibers and the seven plastics that could remove a part of your swaddle blanket or the whole swaddle blanket from phthalates testing Plammability testing would not apply to children's blankets or swaddle blankets because they're not meant to be worn as clothing But please note wearable swaddle blankets could be subject to 16 CFR 16 10 for wearing apparel 16 15 or 16 16, which are the two children's sleepwear standards that vary by size Depending on how they're advertised But again outside the scope of today's discussion just wanted to bring that to your attention because that is a question We get quite often and for small parts testing On whether children's blankets or swaddle blankets require them the answer is maybe If the blankets contain non-fabric fasteners such as snaps or buttons, then they would be subject to small parts testing for blankets that also include a stuffed toy Total leg content testing will apply The fabric would be would fall likely under the materials determinations at 1500.91 Snaps buttons or other non-fabric adornments would be subject to lead substrate testing Lead in paint may apply if paint or surface coatings are on the product For phthalates testing toys and therefore blankets plus stuffed toys Are subject to phthalates testing? But again, we've got those two materials determinations for phthalates For flammability testing it depends on the product design Toys and therefore blankets plus stuffed toys that are intended to be used near a flame source Are subject to flammability testing under the toy standard astm f 963-17 Flammability testing while included in the toy standard is however not mandated for toys and Blankets plus stuffed toys that are not meant to be used near a flame source per the cpsia section that is highlighted on your screen small parts testing would apply to the blanket plus stuffed toy because It is subject and must comply with the toy standard and the toy standard contains a small parts testing requirement All right, so let's talk about what it means to be a small batch manufacturer and some of the benefits of registration To be a small batch manufacturer, you must meet gross revenue standards meaning you cannot exceed 1.18 million In revenue for last year and you can have manufactured no more than 7500 units of the covered product The benefits to being a registered small batch manufacturer Are that you can potentially avoid third-party testing at an independent cpsc accepted lab But you must be in the category of tests that allows this to happen and it only works for certain children's products You can find out more information about the small batch manufacturer program by visiting the small batch page Which is hyperlinked in your handout Of note here, I just want to bring this to your attention That small batch manufacturers do need to make sure that they still comply with applicable requirements and must still prove compliance So you may need even if you are a registered small batch manufacturer to conduct third-party testing and there are examples in group b on our small batch page of products Which a lab test is not required for group a a cpsc lab test is required Lead in paint and small parts are two examples of tests that require cpsc Lab testing so if you need that testing done on your product Then unfortunately you would not be able to avoid the cpsc accepted lab test Even as a small batch manufacturer So, uh, how do you find a lab? You find a lab by visiting our lab search page, which is hyperlinked on your screen. We have um Kind of re-envisioned and redesigned this page To I think two maybe three fiscal years ago And now you can search by region and specifically by country You can also search by testing scope and it's a lot more user friendly There is a nice demo video that our office put together that's available on our website That's also hyperlinked in the handout that will show you how to This filter down the lists of labs and the searches to find the labs that That you need and could help you testing frequency We've got the periodic testing rule requirements here The thing to really remember is the vast majority of manufacturers and importers Are likely going to need to test their children's products Once per year and by and large that is the rule that we see To get your products tested, you will need to submit samples to the lab The lab will perform the applicable testing and provide you testing results We do recommend that to lower your cost. You want to try to find a single lab that can do all the testing that you need done Uh, and the testing needs to be completed before you import the goods into the united states Or if made domestically before you begin distributing them in commerce If you make a material change That is something that uh, you know, would impact how your products perform in either the chemical and mechanical or sorry chemical or physical and mechanical testing Then you will need to have them tested again Um, more regularly than the one here. So you must test initially You tested the material change and then the default really is testing each year Um, important thing to remember here is that manufacturers and importers of children's products Are ultimately the ones that are responsible for preparing a children's product certificate All children's products if they're meant for children ages 12 and under require a children's product certificate And we've got samples on our website via the hyperlink that is shown on your screen There are two samples there for children's clothing. So that would work for bids And a children's toy. So that would work for the blanket and stuff toy combo A few takeaways on certificates before we get into the three examples Certificates need to accompany a product or shipment into the u.s They need to be furnished to each distributor or retailer that you're working with You don't have an obligation to provide it to the ultimate consumer But they must be provided to our agency and customs upon request electronic certificates are Work just as well as paper certificates by rule from our commission However, electronic certificates must be created no later than the time of shipment if the product's being imported into the u.s Or first distribution within the u.s. If made domestically All right, let's look at three children's product certificate examples The first is a fabric bib with plastic snaps and plastic saw based screen printing So I mentioned that a children's product certificate has seven sections These are the seven sections in section one You're going to provide a description of your product in section two You're going to cite to the safety rules that apply and remember the charts that we just went through These are straight from those charts So a fabric bib with plastic snaps and plastic saw based screen printing It's going to be subject to total leg content. All children's products are it's got plastic saw screen printing So it's subject to lead in paint and surface coatings It's subject to phthalates because bibs are subject to phthalates testing And it's subject to flammability because bibs are wearing apparel At section three, you're going to include your importer or manufacturer contact info At section four, you're going to include the contact info of the person maintaining the test records for your company Five is the date in place of manufacture of your product And six is the location of testing and the date of the test on which the certification is based And of note here if you are relying on testing determinations You need to cite the applicable regulations in section six So here we have cited the total leg content determinations for fabric 1500.91 and also the flammability testing Determination or exemption for plain surface fabric more than 88.2 grams per square meter of 16 10.1d So those should go on section six Section seven of your certificate is the contact information of the testing lab And if you have one the small batch manufacturer registration number for your company So a burq clock again children's product certificates same Seven sections the only distinction here is going to be in section two and section six Section two total leg content is going to apply It does to all kids products Lead and paint and surface coatings applies because we've got painted metal snaps and small parts applies because burq costs are subject to small parts testing If they contain things like metal snaps and aren't just fabric Section six we've cited the testing determination for total leg content, which is for fabric And lastly our 100 fabric baby blanket Again, only distinctions here in section two and section six Our section two has the total leg content testing that applies to all children's products And phthalates testing because this is a baby blanket So it's meant for a child under three and facilitate sleep In section six we've cited the total leg content fabric determination at 1500.91 And the phthalates determinations for unfinished manufactured fibers at 1253.2c in section six All right, let me highlight a few Recalls because I know we're running short on time and then I'll take just a few audience questions I will wrap up for the day the first recall example and the reason that we do this is not to You know pick on any of these manufacturers or importers that were part of this recall process It's truly to help point out some of the issues that other Companies have experience so that when you're designing your product and you're making your product and sourcing your Parts that you can do so in a way that would not get you on the recall site because we all want to learn From, you know, everybody's collective experiences So the first is a bib that was recalled because the snaps on the back, which you can see there Are two snaps on the back could detach and pose a choking hazard to children These were recalled in 2019 and there were 7 000 of those recalled Another recall associated with bibs. These were children's waterproof bibs The waterproof plastic backing could separate from the terry cloth fabric and that posed a suffocation hazard so This was a product defect Here because there is not a suffocation hazard test associated with bibs But because this posed an unreasonable risk of injury It was part of a recall in 2017 and 10 400 packages of these waterproof bibs were recalled This is a children's security blanket that was recalled because again the snaps could detach posing a choking hazard So it is worth pointing out here that even if your product is not subject to Small parts testing because of the way it's designed or marketed If it contains snaps or buttons or something that could potentially come off Even if you're not subject to small parts testing you still want to make sure that those snaps and grommets and toggles Are securely Placed on the product such that they're not going to end up coming off because if they do Regardless of whether you're subject to small parts testing requirements. They still pose a choking hazard and would necessitate a recall and a reporting to cpsc and then That that is absolutely something that you want to avoid So the last recall example and this is actually children's clothing But we brought it up because it has to do with total lead content just so this is top of mind for you guys This was actually a metal pendant on the necklace. That's part of this children's dress That had high lead levels So if you are incorporating metal into your children's products They are subject to the lead substrate or total leg content 100 parts per million limit And you want to make sure that you're having testing done on those metal parts because that could Be part of a recall just like With these girls clothing in a 2018 5300 units All right, so I will take a few audience questions. I just want to point out some resources We've got business education pages available on our website They are organized by product type and again that hyperlinks in your handout I already talked about the lab search page can't say enough good things about the regulatory robot It's available in seven languages It will walk you through very few questions takes you just a few minutes to answer Each of the questions bibs vert cross blankets all consumer products are covered there It will give you an end report that you can share with others and all right I see that we are at the end of time Two last resources to point you guys to our business education playlist I mentioned we're making a video of today's we've recorded today's presentation Once we download this video, we'll upload it to our business education playlist Which is available on youtube via that link cpsc webinar series And if you would like to find out about more webinars, we put these on pretty regularly actually we're I think we're averaging You know one every month every month or two If you'd like to know when we're going to have our next one, please do sign up for our spio newsletter You can do so at cpsc.gov forward slash email Select small business ombudsman updates and you'll be able to Get our monthly newsletters, which we try to send out towards the end of each month So with that I want to say thank you at your last opportunity to download the slides via handout and to submit questions here If you'd rather send questions to us directly You can do so by submitting them to my email smathis at cpsc.gov or emailing the spio team at spio at cpsc.gov Or call our business line at the number on your screen Leave us a voicemail with your name email and phone number and you will get a call back from us Thank you so much for attending. I am Shelby Mathis the small business ombudsman I really appreciate your attendance and I hope you have a great a great rest of your day