On Wednesday, October 26, 2011, the 36-member Coalition of Small Batch Importers debuted before the Consumer Product Safety Commission.
Said Lynn Persson of Terra Experience in Madison, WI, “I can’t tell you how much it means to see a face representing the small artisans and their importers!!! Thank you!!!” It was the unceasing energy exhibited by the businesses right up until the panel began that really drove the Coalition’s effectiveness. As Marideth Sandler gathered her papers to sit at the panelists’ table, she received emails from Mac McCoy of dZi and other fair trade importers and retailers wanting to join the Coalition. Talk about a collective voice wanting to be heard!
Three Commissioners heard Marideth’s testimony on behalf of the Small Batch Importers. She expanded it with more importer and producer specifics, based on the most recent Fair Trade Federation’s Trends Report, which clearly interested the Commissioners. Her testimony followed the first panel at which four members of the Handmade Toys Alliance testified. They were instrumental in helping write and support HR 2715 which, when Congress approved it and the President signed it this summer, authorized different treatment for testing of children’s products by small batch importers and manufacturers.
The Commissioners listened and asked a number of questions. It is difficult to know whether the Commission will act before the third-party testing requirements go into effect on January 1 or whether the bill’s “trigger” will pull that would approve exemptions in the event of no action by the Commission before January 1.
Why is this important?
Right now, as of January 1, 2012, all children’s products will need to be “third-party” tested by an independent lab to ensure conformity with flammability, lead, phthalate, and toy safety requirements.
However, for manufacturers and importers who do less than $1 million in business annually and either manufacture or import individual products in annual amounts less than 7,500 units – there may be the opportunity for approval of an alternate testing mode or exemption from the third-party testing.
That does not mean that the manufacturers and importers will NOT need to comply with the standards. They still will – but not be required to have the products tested by a certified lab to ensure that. Many supplying countries do not have certified labs or the lab is located far from the artisans’ communities.
All children’s products will need to be tested prior to entry into the U.S., although we are working with the CPSC to see if there is a way for the products to be tested in the U.S. after entry if there is no certified lab in-country.
The tests are also expensive when realizing that they may cost as much as the entire product shipment into the U.S. for an entire year.
The Small Batch Coalition’s comments are at http://bit.ly/shJm0k