so the stay of enforcement is set to expire, again, in February. The 10th or the 20th, I Don’t remember for sure which one.
The CPSC has had a whole year to figure this out. They haven’t. They’ve had a whole year to do what they keep hinting they might do, which is allow component testing. They haven’t.
If they continue to do nothing, I will be back in the same position I’ve been in every February for the last 3 years. I’ll need to have every product tested.
The only sort of good news about this is that in the last year, the CPSC has released guidance suggesting that they don’t see different fabric options as being different products. This means that I could have ONE fitted diaper tested, and as long as the only difference between that fitted diaper and another fitted diaper was the print on the outside of the fabric, I would not need to have it tested as well. This actually doesn’t make any sense at all, since the different prints would have different dyes, and might be manufactured in different facilities, but whatever, i’m not looking a gift horse in the mouth.
But, following this logic, doesn’t it make more sense to allow component testing? YES it does! Under component testing, I would need to test each component (like PUL, or snaps, or elastic) one time, instead of multiple times. (Under current testing rules, my elastic would get tested three times – when i did a fitted, when I did a pocket, and when I did an AIO.) Under component testing, I could actually get away with very little testing. My snaps are already certified lead-free. The Touchtape is. The fabric has been exempted. The only things I’m not sure about are the elastics and the threads. (I mean, I’m certain they’re lead free, but I’m not certain I have documentation to back that up.)
The really crappy part about this is that the CPSC tends to act only when there’s just a few days until the deadline. This might be OK for large companies, who can have testing runs at accredited labs all set up and they just need to pull the trigger. But for us smaller companies, it’s a real nightmare, and makes planning impossible. I am not big enough to have testing labs allow that kind of arrangement. And I can’t afford to have things tested if I don’t need to.
This leaves me in the unenviable position of having to wait and see, and then scramble with all the other little people for a slot at the testing labs, waiting to sell any product until the test results come back.
The financial aspect is what scares me, though. Under even the most conservative estimates, we’re still taking several hundred dollars per product. This means raising prices, and dumping more product lines. I still am sad that I had to dump doll carriers and doll diapers after the phalate testing requirements. I’ll have to dump even more this time.