Loopholes in Product Safety Law Put Compliance Burden on You
One reason for these challenges in our industry is that most promotional products are not "children's products" as blank, undecorated products. Non-children's blanks only become children's products if they are decorated with a juvenile design and even then only if the products are "mainly" for children 12 and under and have declining appeal to older kids.
Suppliers deal with this blanks-that-could-become-children's-products challenge individually. Some test all of their products to children's product standards, some indicate on their websites the specific products which have been tested and for some you may have to make a call to find out which products are compliant and have been tested. The most important point is that the burden is on you to find this information out before you place your order, to avoid selecting a product which has not been tested as compliant.
In summary, when kids are part of the audience for the products you sell, my advice is to ignore the loopholes in CPSIA and insist on choosing products that have been tested by a third party lab as compliant with children's product regulations. Just keep reminding yourself, "If children are involved, would my client expect the products I'm recommending to have been tested to children's product standards?" Let that be your guide and you'll never go wrong.
Rick Brenner is CEO of Top 40 promotional products supplier Primeline.com, founding board member of Quality Certification Alliance (QCA), chair of QCA’s compliance committee, newly elected board member of Promotional Products Association International (PPAI) for the 2012-2016 term and a member of PPAI’s Product Responsibility Action Group. The opinions stated here are strictly his own and do not necessarily reflect the views of any of these organizations. Contact Rick at firstname.lastname@example.org.