I have been looking into the federal regulations on stuffed animals and after speaking with a federal representative, Dollie Nicholson, regarding flamability testing required on all stuffed animals, no exceptions for home crafters, I have decided to pull my two animals from my etsy store listings. I am feeling very angery and frustrated. Here is the correspondence. What do you think of this?
Dear Ms. Becky:
It was a pleasure talking with you yesterday. I am Dollie Nicholson a compliance officer with CPSC. I am responding to your inquiry concerning testing of stuffed toys. For your information:
1. There are no federal safety flammability standards for stuffed toys; however, there is a voluntary standard that all stuffed toys must conform with.
The voluntary standard is in the toy specification ASTM Designation F963-07. It provides very specific instructions on the test methods for stuffed toys.
The purpose of the test is to determine if the entire toy bursts into flames within a specified time. ASTM International, 100 Barr Harbor Drive , PO Box
C700, West Conshohocken , PA , 19428-2959 , www.astm.com
2. I am not aware any laws or standards to make fabrics fire resistant/retardant.
There are CPSC requirements for stuffed toys that your product must meet. They are:
use and abuse tests
1500.50 (also pdf)
1500.51 (also pdf)
1500.52 (also pdf)
1500.53 (also pdf)
painted with lead or containing lead
Guidance for Lead in Consumer Products
Metal Jewelry Enforcement Policy
Metal Jewelry Test Method
Metal Jewelry Health Rationale
US Candy Importers: Lead in Wrappers
Mexican Candy Producers: Lead in Wrappers
Mexican Candy Producers: Version Español
Lead Testing for Children’s Metal Jewelry FAQ
Please visit www.cpsc.gov for more information. You may contact me should you have questions or concerns.
Dollie W. Nicholson
*****!!! Unless otherwise stated, any views or opinions expressed in this e-mail (and any attachments) are solely those of the author and do not necessarily represent those of the U.S. Consumer Product Safety Commission. Copies of product recall and product safety information can be sent to you automatically via Internet e-mail, as they are released by CPSC. To subscribe or unsubscribe to this service go to the following web page: https://www.cpsc.gov/cpsclist.aspx *****!!!
Dear Dollie Nicholson,
Thank you for sending me the information. I will not be listing them as toys. I will be selling them as soft sculptured collectibles (fabric sculptures) for adults and teens and specifically informing customers that they are not intended for small children.
It is unreasonable to require a craftsperson, who is not a manufacturer, to pay a lab to have their few handcrafted creations burned. They are very time consuming to make. I only make a few of them and the materials cost me a lot of money. Each animal is made with a different plush so I would essentially make the various animals and pay someone to burn them all up. What kind of sense would that make? These are not samples of hundreds, or thousands, or millions of the same identical animal. They are essentially each unique works of art. I make them using the best materials and only new, pure polyester fiber stuffing. I reinforce all of the stress points and use plastic eyes and noses secured with lock washers inside the animal. I don't attach ribbons or any other small parts. I never put wires or other sharp things inside.
Thank you again for taking the time to talk with me and send me this information. Now I am most interested in knowing what terminology I specifically need to use to disqualify my soft sculptured creations from being tested by fire. What would I need to say in the description that would make it clear that these are not toys? Can you send me links to information about who/what is exempt and how to be exempt? Thank you.
Dear Ms. Flaming-Martin:
Stuffed animals are intended for use by children of all ages. This includes children under the age of 3. If you stick a label that states your product is intended for teens and adults, that conflicts with the age labeling guidelines.
So, dear readers, I have decided not to sell my lovely handcrafted stuffed animals anymore. I will continue to sell the patterns.