I’ve had information that by August 14, retailers must have permanent labels on all of their children’s products – including information about when the item was manufactured – what location and what run – all the tee shirts that I have came from different times, and I have no clue as to when they were made, nor what the run number is.
Same with the embroidery thread.
And of course all the cotton fabric I have was purchased at a number of locations and times.
Someone asked me yesterday that since I was using textiles, wasn’t I exempt. There seems to be conflicting answers. However, I think what’s going to happen, is that in Feb 2010 – all items must be tested. That’s not an option for the tee shirts I use – since I have no idea which shirts that I have on hand were made at the same time – my inventory of blank tee shirts for children, turns over fairly quickly for some sizes and not for others. Do I test all of my tee shirts at once? What happens when I order more? Do those need to be tested?
Another thing that bothers me, is that each item needs to be permanently labeled with my store name, my name, contents, phone number, etc. Sewing a label is not an option as that can be taken off. So on a custom tee shirt for a child, I’m supposed to use permanent marker? I don’t think so!
I could be wrong, and all of this will change when congress decides that their regulations are too convoluted. But at this point – I’d rather take the safe route, not open myself up for lawsuits, and just fold my hand.
So as of August 14, 2009 – I will no longer be offering tee shirts for children – in any way on my website. You still have 8 days, in which to order children’s tee shirts – be sure to check out my website Sandi’s T’s and order while you still can!
Because I offer crib sets, toddler throws and bows for infants – I’m now in touch with the companies involved, to see if they will be able to comply with the upcoming labeling of items.
You do have somewhat of a misunderstanding about the labeling/testing requirements. You don’t need to know the run numbers of your materials – only YOUR run number. For my business, many of my runs are single item runs, so for MY purposes, the date of manufacture (or month of manufacture) IS my run number.
A sewn on label IS considered to be permanent. Yes, it could be removed, but it is not normally removed in the course of regular use of the item. (A hang tag is NOT permanent, nor is a stick-on label.)
It think for your business, the labeling requirements are doable, but it would be a matter of whether or not it’s worth it just to hang on until February.
I also make babies onesies and T’s.
it might help you to know, that the labelling requirements are for anything manufactured AFTER the Aug date. So all pre existing stock is fine without.
T-shirt lady:
You don’t need to know when already-made items were finished. The tracking labels are for items made as of August 14th and forward…it is not retroactive like the lead and phthalate limits.
Also, for small manufacturers you do not need to include or track any sort of lot/batch/run numbers. You DO need to be able to tell what materials an items was made of based on when it was made, which is a much easier process to put in place on your side that the customer never needs to see on a tag.
I hope that helps!
-John Greco
Greco Woodcrafting