How can I find out what I am required to do to comply?

[Audrey Fisch]

This may not be the place for this, but I have not even been able to figure out what we are currently required to do.

I am a sales representative (not an importer) for a small British company that manufactures a potty training sticker which adheres to the bottom of a training potty. It is not really for use by children per se as it shouldn't really undergo much handling by them. So are we a "child's product"? We do also sell plastic potties.

So - what do we have to test for, if anything, and what's the deal with the certificate? I have retailers telling me it is illegal for them to sell my product and I of course cannot get any help from the cpsc.

Thanks!

[Desiree Vittorio]

yea! They did not even mention training pottys! You can email the CPSC a request for exemption since really, a child probably should never put such an item in their mouth and it is for sure not a toy. Maybe try calling Patti Bittner who is the CPSC Small Business Ombudsman (888-531-9070).

[Audrey Fisch]

Thank you! I will try that.

[Audrey Fisch]

When I called the ombudsman number there was a recording advising that they cannot respond to any individual requests for assistance.

[Tim Saylor]

Really, you need to begin with defining the category that your products fall into. From there, you can determine what rwquirements it needs to meet. From the sound of it, you have a "children's product", so you would not be required to test for pthalates. However, you will need a test report showing compliance with lead limits for surface coatings and paints, if they are accessible. Beginning in February, CPSIA requires testing for lead in substrates as well. Depending on the age grade of the product (most likely <3 years), you will need the report to reflect that it complies with FHSA small parts rwquirements as well. Determining the applicable rwquirements begins with the product intent and age grade. There are certified labs that can perform this testing, but the most coat effective are in China (typically 1/4 of the testing costs ofthe US labs).