April '17

For the Business of Apparel Decorating

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48 || P R I N T W E A R A P R I L 2 0 1 7 principle outlined in the regulation. There are some exceptions based on production testing plans and use of an ISO/IEC 17025-2005-accredited lab that can extend the timeframe but that rarely applies here. In- stead, the key here is that you must obtain valid test reports from your decoration suppliers, such as ink or heat transfer manufacturers, and provide them to the promotional products distributor, if applicable. The CPSC and test labs have a wealth of informa- tion on the topic. Certificates of conformity: Certificates of confor- mity provide confidence that a product, process, or service is in accordance with a specific standard. The manufacturer (distributor in this case) is required to draft and issue a Children's Product Certificate (CPC). The CPC is a certification of conformity that is issued under the rules of a certification system by which the "manufacturer" certifies that its children's product complies with all applicable children's prod- uct safety rules. Per the CPSC, certification of children's products must be based upon passing third-party testing. The third-party testing laboratory provides the testing services and results but does not issue the CPC. The manufacturer or importer may draft the CPC by it- self, based upon the passing test results of the third- party testing. The apparel supplier will produce or have on-hand from the manufacturer a CPC for the garment. It should address any components that are part of the garment (e.g. ink, zippers, buttons, and decorations) and flammability per 16CFR part 1610 of the Flam- mable Fabrics Act (FFA). Tracking label: Tracking labels are required for all children's products and packaging whether they are domestic or imported, with rare exception. The intent of the tracking labels is to enhance recall ef- fectiveness. In the event of an incident or issue with the product, the tracking label will provide informa- tion to the end user that directs them to the company responsible for maintaining the compliance records. Tracking labels must include: • Manufacturer name—in this case, it would nor- mally be the distributor's name but could be yours as the decorator • The month and year decoration was applied • The city and state where decoration was applied • Identification number (this could be the decora- tor or distributor's batch number, internal order number, purchase order number, or other identi- fying number associated with the order) • Other information specific to the product (e.g. red shirt G200B—camp logo) • Contact information (email or phone number) SUMMARY In summary, if you keep these points in mind, you will be on your way to successfully managing the CPSIA as it relates to decorating youth apparel. Re- member that violating the requirements of the CP- SIA and otherwise failing to comply with section 14 of the CPSA could lead to a civil penalty and possibly criminal penalties and asset forfeiture. If you take these points to heart, document and implement appropriate processes for complying with CPSIA, and then clearly demonstrate this to promo- tional products distributors and other clients, there is a very good chance that your business will grow. So now, back to my original question. Whether it has been one request or numerous related to CPSIA, how will you respond? CPSIA COMPLIANCE

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