Let's talk registration, shall we?
Registration with the Consumer Product Safety Commision (CPSC) is the very first step I tell product-based businesses to do for product safety compliance. This registration is free and does a few things for product-based businesses.
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Where did this Small Batch Manufacturer registry come from?
When the CPSC was in discussions on improving the Consumer Product Safety Act, a lot of things proposed would change how small businesses could function. The proposed Consumer Product Safety Improvement Act of 2008 was publicized and the fears of small businesses were real. How could they afford to keep up with these requirements?
The Handmade Toy Association took a stand for all makers in, and selling to, the US. They encouraged the CPSC to take another look at the CPSIA of 2008 and showed them the increase in burdens that would put most, if not all, small businesses out.
Because of this push, the CPSC found an agreeable solution. You see, the CPSC is not aimed at destroying small businesses. In fact, they wanted to help small businesses stay successful! The CPSC focuses on safety above the usual back and forth politics.
- Small Business Ombudsman. One solution for small businesses was giving them an active voice when they don't realize they have one. The Small Business Ombudsman is the reminder during discussions that small businesses are impacted and part of the SBO's job is to make sure those impacts aren't too burdensome. Another part of their job is to be an acting bridge between the commissioners and small businesses when interpreting the laws in specific regards to small businesses. That is, when you contact the SBO directly, they will assume you are a small business and will discuss matters from that view point.
- Small Batch Manufacturer registry. As I'll expand on below, this provides some monetary relief of testing burdens that plague small businesses otherwise. While the Handmade Toy Association was unable to get everything they wanted and still had some lab testing they were required to do, they were given a breath of fresh air that they didn't have to repeat any already-done testing.
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Register & Respond
It is important to understand that there are actually two parts to registration for Small Batch Manufacturers.
- The first part is for all product-based businesses. Registering for an account with SaferProducts.gov allows your business to abide by the laws of reporting in which you are required to report a safety concern within 24 hours of receiving a complaint. While this can be done via postal mail, there is a reason it is called "snail" mail. The longer it takes to address a safety concern, the more risk for additional problems (like injuries) to occur. This account also provides a place for your business to quickly respond to a complaint. Complaints can be done by the business itself, customers, shoppers, advocacy organizations, and anyone else, including competitors. Failure to respond in a timely manner can mean the business could see fines and/or recalls.
- The second part is specifically for Small Batch Manufacturers. If you've already gone through this process, you likely didn't even notice the first part because they've set up the system to allow registration for both to be done at once (which is really nice). As a mid- to large- sized manufacture, you would be required to test on your own for all applicable requirements, or make certain that the test reports you've received from suppliers are truthful, under a year old, and completed at a CPSC-accepted lab. This means that if a fabric needs to be tested for Flammability of Wearing Apparel, you must have a lab report in your records.
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Benefits for Makers
As a small batch manufacturer, you are able to rely on some supplier statements (paints must have a report; small parts must have a report on the final product). This means that if a fabric needs to be tested for Flammability of Wearing Apparel, you can obtain just a statement that the testing has been done.
Additionally, this number allows you to do some testing on your own instead of at a lab! Let me tell you, this is a HUGE bonus because testing for only the physical/mechanical tests for toys typically runs $300-$600 per toy and labs will typically request 3-6 identical samples. Being able to purchase the ASTM F963-17 publication (or reading it for free in the Reading Room) and testing it on your own saves you time, money, and inventory!
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** As a note, even a registered small batch manufacturer *must* follow all applicable regulations. We do not get a pass to not follow any regulation, we simply have the benefit of relying on our trusted suppliers that proper testing has already been done on our components. We must still be able to create a children's product certificate self-certifying that our products are compliant based on the gathered information from suppliers, our own testing, lab testing, and allowable exemptions.
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Check out these other resources to help your journey.
- Process Series: Registration how-to video & downloads
- The Makers Community
- Free US Product Safety Compliance group on Facebook
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