Tonight, I wrote my Senators. If you haven't heard about the Consumer Product Safety Improvement Act, check out the Handmade Toy Alliance website. In a nutshell, the CPSIA was enacted in response to the consumer wrath over all of the recent recalls of children's toys found to have unacceptably high levels of lead. Among other things, it requires third-party testing of all goods aimed at children under the age of 12 for chemicals such as lead and phlalates. Sounds good, right? I'm against my kids being exposed to lead and phlatates (I'm also against Bisphenol A, but that's another post), who wouldn't be?
The problem is that the act does not provide any provisions or exemptions for small businesses and crafters and, as currently stated, requires testing of each item produced. I read one blog (I can't find the darn link now) that said one work at home mom got estimates on testing the onesies she embroiders and it was something like $600 per onesie. What does this mean? It means all that cool kids stuff you've been eyeballing at Etsy will disappear. Work at home moms who produce things like baby carriers, cloth diapers, and baby blankets will have to close up shop, or only sell within state lines (bye, bye internet sales!). What about small US toy makers that produce, and have produced for years, toys that are produced using natural, non-toxic materials? Too bad, they also have to submit to the prohibitely expensive testing.
As you will see in my letter, I'm not against the testing and protecting kids, just the way the CPSIA requires that the testing be done. Read on!
Dear Senator Murray,
I am writing in regards to the Consumer Product Safety Improvement Act (CPSIA). As a consumer and soon-to-be mom, I was thrilled to see congress take action to protect the nation's children from dangerous chemicals and substances found in toys, clothes, and other consumer goods aimed at children.
Unfortunately, the consequences of the CPSIA's third-party testing requirement on small businesses are devastating, unacceptable, and unnecessary. Requiring unit-based testing and labeling unfairly favors large manufacturers who make thousands of units of each toy and will have very little incremental cost to pay for testing and update their molds to include batch labels. The cost of testing for small businesses will be prohibitively expensive and has lead to many to refer to February 10th, 2009, the date by which manufacturers must be in compliance, as National Bankruptcy Day. By driving these small crafters and companies out of business, not only does the CPSIA strike another blow in an already fragile US economy, it serves to decrease consumer choice and inhibit free enterprise. The irony of this law should be clear: those large manufacturer's, many of whom outsourced manufacturing to countries with fewer regulations and controls such as China, whose products and practices the CPSIA was meant to address, will benefit from decreased competition. Meanwhile, many small companies who have long upheld and surpassed consumer safety and environmental standards, while keeping jobs in the US, will be crushed under the weight of this legislation. There has to be a better way-- and there is.
As a registered voter in Washington state, I expect you to take action to ensure that appropriate changes and exemptions are made to the CPSIA that protect small businesses, while continuing to protect children. Suggestions, include allowing materials-based certification instead of unit-based certification, which would make it possible for crafters and small businesses to rely on certifications from their materials suppliers instead of repeating tests multiple times for each product made from those materials. The National Association of Manufacturers has presented a petition to the Consumer Product Safety Commission, proposing changes to the CPSIA, including the above, that are endorsed by organizations such as The Handmade Toy Alliance. I urge you to review and support the petition.
Finally, I would like to be clear that the above letter is not a canned letter taken from some advocacy site. This issue is one that I, as a private citizen and consumer, have taken the time to research and write you, as well as Senator Cantwell, about. I know that generally, emails are not as highly regarded as physical letters, in this case I chose to send this letter by email not out of convenience, but because this is a pressing issue requiring a timely response.
Thank you for your time and attention to this issue.
Sincerely,
(my name here)
As an aside, already at least one European toy maker has announced intentions to pull out of the US toy market due to cost concerns and because the of US regulations. They are already in compliance with the European standards and the costs for separate testing for the US would make the toys too expnsive to be competitive in the market.
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