It’s the start of the Christmas baby doll buying season and dolls cost more this year. Why?
Fuel and transport costs.
Rising labor costs.
General inflationary pressures.
But to a large extent… new toy safety regulations passed in August by the Consumer Product Safety Improvement Act.
Lead:Scope: Materials and substrate of any children’s products.
Requirement: The limits on lead in children’s products will be established as follows and according to this timetable:
1. 600 parts per million (ppm) – effective 180 days after enactment of the Act
2. 300 ppm – effective 1 year after enactment of the Act
Lead in paint and surface coatings (Sec. 101, part (f))Scope: Children’s products
Requirement: The limit will be reduced from the current 0.06 percent (600 ppm) requirement to 0.009 percent (90 ppm).Testing: The Act allows for consideration of alternative methods of testing for lead in paint including x-ray florescence technology (XRF) when the total weight of the paint or surface coating to be tested is no greater than 10 mg or no more than 1 cm2 of surface area. Additionally, the Act calls on CPSC to study the effectiveness, precision and reliability of XRF and other alternate methods for measuring lead in paint and surface coatings – and if determined to be at least as effective, precise and reliable as other methods the agency may promulgate regulations governing the use of such methods.
Expense : Testing – Every Doll now has to be tested. That means you need the ‘sniffers’ that can actually detect lead content. Not cheap.
Expense : Reporting – Not only do you have to get good results, but now everyone down the chain has to have them too… from the giants like Wal-mart and Target, to little ole’ me and our three online doll stores.
Expense: Compliance officer. There is so much regulation, testing and reporting needed, that the manufacturers are hiring folks to oversee their compliance. And these folks need to go to China pretty often as well. Expensive.
Tracking Labels for Children’s Products (Sec. 103)
Scope: Children’s products
Requirement: Effective one year after enactment of the Act, manufacturers must place permanent, distinguishing marks on a product and its packaging, to the extent practicable, that will enable the manufacturer and ultimate purchaser to ascertain: the name of the manufacturer, date and location of production and identifying production information (cohort, batch, run number or other identifying information). This provision recognizes that flexibility is needed for different types of products and allows the manufacturer to use its own tracking systems.
This section also stipulates that advertising, labeling or packaging of a product, if it references a consumer product safety rule or standard, must be in compliance with that rule or standard.
Expense: Data Entry, Printing costs, Additional employees. Every baby doll, needs to be identified, labeled and tracked from the factory right into your hands. That’s every single, solitary doll.
Labeling Requirement for Advertising of Toys and Games (Sec. 105)
Scope: Retailers, manufacturers, importers, distributors, private labelers of toys and games
Requirement: Any advertisement that contains a direct means for the purchase or ordering of product, must also contain any and all applicable cautionary statements that are already required under the FHSA on or near the product. (e.g. If a game has a small parts warning, this cautionary statement must be repeated in any point-of-purchase advertising such as a catalog or online retailer.). The legislation stipulates the language, type style and layout that must be used in the cautionary statement in advertising. It is incumbent on the manufacturer, importer or private labeler to inform the retailer of such a requirement for the product in advertising and the retailer to inquire of the supplier. CPSC, within 90 days of enactment, must promulgate regulations related to this requirement. Effective 120 days after enactment for internet websites; 180 days for catalogs and other printed materials.
Yup, that’s Addie and I… we advertise on the internet, so we need to go back and check that every single product has the right wording, the right layout, the right type size and the right location as specified by this law. (We are still waiting to find out the particulars from the government)
There’s more, but we think you get the point. Even though we have never had a product recalled, even though we have always made it a point to do age recommendations, the rules are stricter and more expensive to comply with now.
But as inconvenient and expensive as this may be, we’re still for it. A child’s life is too important. We will do whatever we can to safeguard it.