The $500 Average Order Dilemma
The issue is further complicated by the nature of our industry where suppliers inventory blank goods and decorate in smaller quantities on demand when distributors place orders. Even if suppliers were on top of their supply chains and did any testing required to ensure safety and compliance of the blank goods, these blanks are then subsequently decorated to create the final product. This decoration materially changed the product and, as such, requires either new testing or component-level testing on the inks used in decoration.
In other words, while the product could be tested for safety, the inks could not-rendering the entire product unproven or unsafe. Don't count on your Fortune 1000 clients accepting the statement, "We think the product is mostly safe, but we don't have time to test all of it before your event." No way.
So how much would it cost to test each of your inks once a year? Roughly, in the mid five figures. Because of the wide range of ink colors used, I've heard estimates as low as $30,000 and as high as $75,000. This cost is one of the reasons why ink companies historically have not been eager to provide test results. If the results do in fact exist, oftentimes the testing was done many years ago as a part of the ink's development protocol and the results are out of date for today's compliance standards and regulations.
This is an important consideration because if those inks are used on children's products or products that could potentially transfer these inks to the skin and be absorbed, they must be tested under CPSIA guidelines or, at the very least, be labeled in compliance with California Prop. 65 guidelines.
Here's the catch: The ink company is not making the testing and/or labeling decisions, you are. So, if you tested the blanks, had component-level testing of the inks and had a process in place to ensure the product was decorated with the inks that had been tested, then you would be okay from a product-testing standpoint. If not, you could be in trouble.