CPSC General Counsel Clarifies Distributor Responsibilities for Children's Apparel
Another strategy is for distributors to continue to sell children's apparel but to purchase it as a finished product from a compliant apparel decorator. Distributors would still want to exercise due diligence that the decorator is complaint—just as they would in purchasing children's products from any supplier—but they wouldn't have the manufacturer's responsibility under CPSIA for testing and tracking labels.
Finally, as with all regulatory matters, in addition to the practical and common sense aspects, the matters discussed in Ms. Falvey's letter are legal issues and I am not a lawyer. Nothing that I have written in this or any other article should be construed as legal advice. All industry participants—suppliers and distributors—would be well-served by consulting with a product safety attorney who regularly practices before the Consumer Product Safety Commission and is an expert in CPSIA matters.
Reference: Falvey Letter Re Decorating and Tracking Labels.