As many of you know, the stay of enforcement has expired, and testing is now required on nearly all children's products items.  Which items, made when, of which materials, is a subject for another time.  However, if you are a small business manufacturer, with sales under $1MM, you can request an exemption from certain types of testing, most importantly the expensive and destructive ASTM tests for products of which you sold less than 7500 pcs.  (see the cpsc page for more details). 

Many, including myself had understood that the deadline to register was 12/31/11, however, in speaking with the CPSC Small Business Ombudsman, Neal Cohen, you can in fact still register, for exempt status for 2012 (based on 2011 sales results). It doesn't seem that there is a particular deadline set, but of course if you are not registered, then you fall under the new CPSIA third-party testing requirements until you do.

My friend Kathleen Fasanella has posted a blog post with additional details about the registration process.

The CPSC has opened registration for small batch manufacturers who wish to take advantage of an exemption from third party testing for certain types of products.  Here is a quote from their press release:

Small batch manufacturers, defined as those who earned $1 million or less in total gross revenues from sales of consumer products in 2011, and who produced in total no more than 7,500 units of at least one consumer product in 2011 can register for calendar year 2012 at www.SaferProducts.gov.  Qualifying small batch manufacturers are not required to third party test for compliance with certain children's product safety rules during 2012 for products which they produced no more than 7,500 units of in the previous calendar year.

This new registry does not exempt small batch manufacturers from ensuring that their products comply with these mandatory standards. Small batch manufacturers must still provide a certificate of conformity, in which the manufacturers certify in writing that their products comply with the applicable regulations. However, except where required by law, the certificate does not have to be based on third party testing.

Effective December 31, 2011, the stays of enforcement on third-party testing and certification for limits on total lead content for children's products, the ban on certain phthalates for children's toys and child care articles, and the mandatory toy standard (ASTM F963) will end. CPSC launched an education and outreach effort to ensure…

The following is a press release from the CPSC regarding sleepwear/loungewear, which manufacturers of such items should be aware of. 

CPSC Reinforces Children's Sleepwear and Loungewear Enforcement Policy to Apparel Industry

Agency standards designed to prevent burn injuries to children

WASHINGTON, Dec. 23, 2011 /PRNewswire-USNewswire/ -- In an effort to remind the industry of their obligations associated with children's sleepwear and loungewear, the U.S. Consumer Product Safety Commission's (CPSC's) Director of Compliance and Field Operations sent a letter (pdf) to manufacturers, distributors, importers and retailers today reinforcing CPSC staff's enforcement policy on children's sleepwear and loungewear.

Highlights in the letter to industry review the definition of children's sleepwear including loungewear as a type of children's sleepwear. The Commission's regulations define the term "children's sleepwear" to include any product of wearing apparel (in sizes 0–14), such as nightgowns, pajamas, or similar or related items, such as robes, intended to be worn primarily for sleeping or activities related to sleeping. This definition exempts: (1) diapers and underwear; (2) "infant garments," sized for a child nine months of age or younger; and (3) "tight-fitting garments" that meet specific maximum dimensions.

In the 1990s, a category of products called "loungewear" was introduced into the children's market. CPSC staff views children's "loungewear," or other…

Any new visitor can see that CPSIA-Central has been "asleep" for the past year and a half.  There are a various reasons for this, including the need for me to focus on my own business and less traffic due to the stay of enforcement.  So it went into hibernation.

However, I feel that now with the stay of enforcement coming to an end, there is a greater need for people to understand the implications of this law, and how to cope with it.  I am therefore putting it back online with the hope of developing this site to do one of the main things it was intended to do, mainly to help small business owners navigate the law.

I also hope to continue the mission of not only finding answers to your questions, but questioning the the law and the application of the law as it continues to be rolled out. 

I expect to be adding some new exciting features in the coming days and weeks which will be of use to you.

In the meantime, I welcome your feedback and your ideas for what you would like to see this site become.  What are your needs?  How can we as a community help you work through the maze of regulations.