“Small batch” importers of handmade crafts and apparel are providing comments and public hearing testimony to the the Consumer Product Safety Commission (CPSC) on affordable and feasible alternatives to complying with the upcoming requirements for third-party children’s-product testing for lead. In doing so, they have asked Sandler Trade LLC to help review the regulations, interview companies, and draft the letter and testimony for the companies’ review.
This a unique and significant opportunity to comment on the difficulty and overwhelming nature of compliance for small importers and manufacturers. Passage of legislation last summer authorized the CPSC to allow U.S. manufacturers and importers with revenues of under $1 million and that import in batch sizes of less than 7,500 pieces to use alternative testing methods and, possibly, to be exempt from third-party testing altogether.
If you are a small importer or manufacturer of artisanal, handmade, folk art, or other items – whether for-profit or non-profit – please consider adding your input to the comments, which are due on Friday, October 21. The public hearing will be on Wednesday, October 26 in Bethesda. Contact Marideth Sandler at sandler@sandlertrade.com for more information.
For details on the input sought by the CPSC through comment and testimony, please go to http://www.cpsc.gov/businfo/frnotices/fr12/smallbatch.pdf The public hearing also will be available live via webcast on October 26, 2011, at: http://www.cpsc.gov/webcast. There is no public participation via the webcast.