April '17

For the Business of Apparel Decorating

Issue link:

Contents of this Issue


Page 50 of 136

I have to believe that by now most contract decorators have received at least one inquiry about CPSIA requirements. Whether it has been one request or numerous, what is your response? Do you know what your responsibilities are under the law? Do you believe that it is not your responsibility? If you haven't been asked, then you may be won- dering what I am talking about. In either case, how you respond is critical. Awareness is critical because it can have a great impact on the success of your business, your clients' reputations, end-buyers' brands, and end-users' safety. In 2008, the Consumer Product Safety Commis- sion (CPSC) passed the Consumer Product Safety Improvement Act (CPSIA). This law established spe- cific criteria for children's products, clothing, and toys. It is difficult for anyone to argue with the intent of the CPSIA regulations as it aims to protect the most vul- nerable among us. However, due to vague definitions and the vast number of products in our society, there have been many misunderstandings and unintended consequences resulting from the passage of this law, especially as it relates to promotional products, and specifically, youth apparel. Over the past year, the CPSC has issued some of the largest fines in its history for product safety violations. Penalties for non-compliance can cost as much as $100,000 for each violation with maximum penalty amounts, for related or repeated violations, ranging from $1.8 million to $15 million. It really doesn't matter if your clients are asking for compliancy. As business owners, you and the promo- tional products distributors contracting your service have a responsibility to follow the law. On a positive note, if you are prepared, then some of the tips in this article should help validate or enhance your current processes. Remember, when embellishing youth apparel, two factors must always be taken into consideration: the garment itself and the applied decoration. THE GARMENT Talking specifically about "contract decorating," you as the decorator do not have to be as concerned with the compliance of the garment. The garment suppli- er—either the manufacturer or importer of record—is responsible for ensuring compliance with all applica- ble standards. The distributor that purchases the youth garment and has it shipped to you for decoration is responsible for protecting their client's brand. They do this by ob- taining current and valid compliance documents from the apparel supplier along with ensuring appropriate tracking labels are visible on the garment. It is impor- tant to note that garment size matters. All children- sized clothing is subject to CPSIA regulations. Do note, that when you, as a decorator, procure the garment from an apparel supplier and decorate it for your client, you take on the same responsibility as a distributor in the scenario mentioned above. Why does my customer require this? Where Responsibility for CPSIA Compliance Lies B Y T I M B R O W N Tim Brown, MAS, is the executive director of operations for the Quality Certification Al- liance (QCA), an independent accreditation organization that elevates the standards for promotional products procurement to ensure safe, high quality, socially compliant and en- vironmentally conscientious merchandise. Prior to joining QCA, Brown spent the last decade as a compliance pro- fessional in the promotional products industry. He got his start in the industry as a supplier relationship manager at Cintas Branded Apparel & Promotional Products. Most recently, he was the product responsibil- ity manager at Promotional Products Association International (PPAI). Before that, he was owner of his own compliance consulting firm. 44 || P R I N T W E A R A P R I L 2 0 1 7

Articles in this issue

view archives of Printwear - April '17