While it is very clear that in August 2009 the new regulations require third-party testing. The February 10, 2009 deadline allows for XRF testing and/or another "reasonable testing program".
So, based on that, until August I can come up with a reasonable testing program and produce a general conformity certificate regarding this program. So what is a general conformity certificate. Well, it just so happens that the CPSC has some guidelines on what that means.
Here's what I've learned:
- Certification means vouching that a product complies with the standard set by the CPSC, In this case lead limits (and phthalate limits if those apply to you)
- Certification may or may not include any laboratory testing
- Certification may or may not include a label or mark on the product
- If the product has a private label (like my BuggApparel does), the private labeler must also issue a certificate
What needs a certificate:
- Certification must be based on a test of each product OR a reasonable testing program.
- All products intended for children under 12 must be tested.
Where do you get a certificate?
- You make it yourself based on the information and data you get from your "reasonable testing program"
What goes on the certificate?
- Certificate must be in English
- It must identify the manufacturer AND private labeler of the certificate issuer
- It must identify the party doing the testing by listing name, address, and phone number
- Date and place the product was manufactured
- Date and place the product was tested
- Contact information of the person maintaining the test records
- Each applicable standard (or ban)
What do you do with the certificate?
- If you are the retailer of your own products: File it away, if someone asks for it, you must be able to produce it.
- If you do wholesale or consignment of your products: Send it with any wholesale order you receive or with any products you intend to consign as the retailer must be able to produce it if asked.
Here is a template for your GCC: http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf
In the upcoming days I'll be talking about XRF testing. I'm currently researching costs and gathering information. Stay Tuned!