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CPSC Announces Registry For Small Manufacturers
Vol. 884 
January 12, 2012

In an effort to provide relief to smaller manufacturers of children’s products, the U.S. Consumer Product Safety Commission (CPSC) has launched an online registry that will allow for certain third-party testing exemptions. The establishment of the registry, which can be found at, comes as the CPSC begins its enforcement of testing standards and certification requirements related to lead and phthalates limits.

In order to qualify for specific third-party testing exemptions (or alternative testing standards) in 2012, a manufacturer must satisfy two threshold conditions: it must first prove that its total gross revenue in 2011 did not exceed $1 million and it must also prove that it produced no more than 7,500 units of a qualifying item. Children’s products that qualify for relief include apparel, bicycle helmets, rattles, rugs, lacker balls and electronically operated toys. Products that don’t qualify for exemptions include cribs, pacifiers, metal jewelry, walkers, bath seats and toddler beds.

Even if a company is permitted testing relief, it must still ensure that its children’s products comply with the Consumer Product Safety Improvement Act and it must also issue general certificates of conformity. Once a small batch manufacturer registers for relief, the company’s name, city, and state will be made available to the public within 15 days. The CPSC expects the registry to promote awareness, simplify confirmation processes and help retailers avoid fraudulent claims of exemption.

The most recent CPSIA stay of enforcement, which focused on lead content in children’s products, expired on December 31, 2011. Any manufacturer that is not eligible for exemptions must now certify that its products have been tested by a CPSC-approved third party laboratory in order for their items to be sold in the U.S.

For additional information on the Small Batch Manufacturers Registry and subsequent guidance materials, click here.

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