The Cost of Compliance with CPSIA - Volume 2

I know you were all expecting XRF Testing – Volume 2 today, and it is coming. I may be putting out another blog tonite or tomorrow. At the latest I expect you’ll have it Monday. But in the meantime, I got a little curious about all the quotes for the digestive lead testing that I was hearing. So I checked the CPSC website for accredited labs and I found one in Pennsylvania (because that’s the one closest to me) that I decided to call.

If you’re curious as to where to get the CPSC accredited lab list, here it is: http://www.cpsc.gov/cgi-bin/labapplist.aspx

Here’s the bottom line for digestive lead testing as it applies to me. I'm only doing the costs for my BuggaMobiles and my BuggApparel. Each component of my item will cost $60:

My line of BuggApparel, I specialize in designs on creepers:
Snaps - $60
Fabric - $60
Thread - $60
Labels - $120
Designs - $3000

Cost of Testing - $3300
Cost of Product to be tested - $300
Total cost to maintain my line of Creepers: $3800

And each time I ran out of any of my supplies, I would need to have the new batch of garments retested. So based on 2008 sales, this testing would net me a loss of $500-$1000 on my line of BuggApparel in 2009. I would have to price myself out of the market just to break even. I would potentially consider reducing my offerings in terms of designs, but that really stunts my creative process. I love coming up with new ideas for new designs. Additionally it would prohibit me from doing custom designs, which is a significant portion of my business.

Let’s talk about my mobiles. I have 13 different styles, 3 sizes, 20+ paint colors, 16 design schemes with over 100+ designs within them. For the purposes of this I have estimated some things or lowered my quantities, so the actual cost would be slightly higher than what this reflects.

BuggaMobiles:
Hoop - $180
Mobile Pieces – $6000
Fishing Line - $60
Paint - $1200
Designs - $6000

Cost of Testing – $13440
Cost of Product to be tested - $300
Total cost to maintain my BuggaMobiles: $13740

For those who are interested in which lab this was:
Chemical Solutions
Mechanicsburg, PA
http://www.chemicalsolutionsltd.com
(717)697-7536

And again, each time I run out of any component from the initial batch, I would need to retest those components. There is no reasonable way to absorb $13740 into my costs. That cost exceeds my total spending in all of 2007 AND 2008. I suppose I could look to limit my offerings significantly in order to bring costs down but part of the beauty of my work is that each one is unique, strung individually, made to order based on the colors my client wants, etc. That aspect, the creative aspect of my work, and the aspect I love most, would be destroyed.

So, I’m simply confirming what we all know to be true, the digestive testing for micro-manufacturers is simply prohibitive financially, among other things. On a positive note, this testing facility understood that I am a one-woman operation running a home-based business and was more than willing to do business with me. Please note this testing is for LEAD ONLY. Phthalate testing is not done by the lab I contacted. Based on these numbers, my business will not survive the next wave of deadlines in August 2009. BuggaLove has been given 8 months to live.