New? Join Today! » Create an Account | Sign In
Printwear Special Report

CPSIA: Implications for Decorators

The lowdown on the legislation… straight from the CPSC

As the designated point person at the U.S. Consumer Product Safety Commission (CPSC) dealing with inquiries from small business, you might guess that I receive many telephone calls and emails seeking answers to regulatory questions. And you’d certainly be right. Every month, I field scores of regulatory inquiries, and I’ve found that many are from people in the business of garment decoration, and specifically, screen printing.

I have heard from solo “mompreneurs,” who want to screen print infant clothing, individual screening shops, and some of the largest textile ink manufacturers in the business, not to mention everyone in between. The one common thread in these conversations is that everyone wants to be in compliance with the requirements of the Consumer Product Safety Improvement Act of 2008 (CPSIA), but they are confused about exactly what being compliant means and where to begin the process.

For those unfamiliar with the CPSIA, the law has fundamentally changed the way the CPSC regulates products designed or intended primarily for children age 12 and younger. Yes, that includes children’s T-shirts, infant bodysuits, children’s sleepwear, and similar items for that age group.

The key substantive changes to requirements for these children’s products and for the screen printing industry were the addition of new regulations limiting the total lead content in the substrates of children’s products, banning certain phthalates in toys and child care articles, and lowering the limits on the permissible amount of lead in paint and other similar surface coatings and substrates.

It makes sense to take a moment to clarify that federal regulations treat the underlying base materials (the substrates) differently from the materials that lie on top of the substrate (i.e. paint or ink). The limits for lead are different for the substrate (100 parts per million) than in the ink or paint on the surface of a product (90 parts per million). Also, while the numbers are “very close” numerically, it is important to know that the test methods for each requirement are different. Therefore, you need to know which requirement you are testing for and why.

In addition to these substantive requirements, the CPSIA added new procedural requirements, including requirements to third party test, using CPSC-accepted laboratories; to issue certificates of conformity; and to affix permanent tracking labels to children’s products.

Substrate or surface coating?

The question that seems to be on everyone’s mind in this industry is how the CPSC views screen printing: Is screen printing a surface coating, or does it bond with the underlying textile in such a way that the CPSC views it as part of the substrate?
The answer, as with most factual determinations, is that it depends. Specifically, it depends on whether the textile ink bonds with the fiber or whether it can be scraped off of the textile substrate.

The majority of ink systems used in textile screen printing are plastisol or water-based. If applied and cured properly, they fuse with the textile substrate and will not be able to be scraped off the substrate. (Of course, each case may vary, depending upon the type of ink system used, the individual characteristics of the screen print and substrate, and whether the screen printer properly cleaned the screens with compliant solvents and correctly applied the inks.)

Where the ink cannot be scraped off the textile, CPSC staff treats the ink as being part of the substrate. In that circumstance, the entire children’s garment part (i.e., both the textile garment piece that is printed and the screen printing on the garment tested together), would be treated as a substrate and must comply with the 100 parts per million limit for total lead content. Other distinct, separable parts, such as zippers and buttons, would be tested separately for compliance with the 100 parts per million limit for total lead content.

Exceptions for lead

Importantly, the Commission has already determined that many natural and manufactured textiles (dyed and undyed) will not contain lead in excess of the 100 parts per million limit, and therefore, these items actually are exempt from testing. (See 16 CFR §1500.91.) If, however, you choose to apply a screen print to such a textile, as discussed above, the resulting garment would need to be tested for compliance with the total lead content requirement.

On the other hand, if you are able to obtain a Component Part Certificate for the ink or paint used to screen print, or you can test the ink or paint used to screen print using composite testing, you may not need to test the entire finished garment and may only need to third-party test the ink or paint.

In so doing, you must remember that testing the ink or the paint is based on the weight of the dried film, not its liquid state. Also, remember that, for composite testing, you don’t actually have to scrape the ink off of the screen printed shirt and destroy a large number of samples; it can be scraped off any substrate, such as a glass slide.

If you intend to rely on the Commission’s determination to avoid testing the textile substrate of your children’s product for total lead content, you must secure assurances (for your records) from your supplier or manufacturer that the materials are, indeed, what your supplier or manufacturer claims they are.

Specialty ink systems

Certain specialty textile ink systems may effectively act like dyes, such as those that are absorbed into the fabric and bond with the fabric substrate, effectively acting like a dye (i.e. discharge and sublimation inks). CPSC staff treats such textile ink systems as a “dye-like ink.”

In such a case, the garment would likely be treated as a dyed textile and would not be subject to any testing for lead in paint or for total lead content. (See 16 CFR §1500.91.) Again, each case may vary, depending on the type of ink system used and the individual characteristics of the print and substrate.


In addition to the limits on lead content in the substrate and in surface coatings, there is also a ban on certain phthalates in child care articles used to facilitate sleeping and eating of children age three and younger. In this industry, CPSC staff has interpreted the ban as applying to sleepwear for children three and younger and bibs, but it does not apply to items such as ordinary T-shirts and similar garments.

If your product is subject to the ban on phthalates, the Commission has stated that it is unnecessary to test and certify materials that are known not to contain phthalates or to certify that phthalates are absent from materials that are known not to contain phthalates. For example, materials such as untreated/unfinished wood, metal, natural fibers; natural latex and mineral products; and paper products (paper, paperboard, linerboard and medium, and pulp) do not require testing for phthalates.

In the screen-printing industry, however, it is highly likely that manufacturers of children’s sleepwear and other similar products will have to test their products for phthalates, given the long history of plasticizers used in many textile ink systems and the shared production facilities of many screen printers.

Finally, all garments for adults and children are also subject to other longstanding, substantive regulatory requirements, such as requirements on the flammability of wearing apparel and children’s sleepwear.

Certification and third-party testing

The CPSIA represents the first time, under federal law, that manufacturers and importers of children’s products are required to third-party test and certify their children’s products for compliance.

Certification means that manufacturers and importers of children’s products must issue a written Children’s Product Certificate (CPC) for each product, which identifies the product, the rule or standard with which it complies, the CPSC-accepted third-party laboratory where it was tested, and other requirements. Certification must be based upon the results of third-party testing. Third-party testing means testing performed by a third party, accredited laboratory that the Commission has accepted to perform the specific tests associated with each children’s product safety rule.

To locate a CPSC-accepted laboratory to test your product, to review a model CPC, and for more details about what third party testing and certification means for your business, please see the links provided in the resource box on the opposite page.

Small-batch manufacturers

In certain situations, qualifying small-batch manufacturers may not be required to third-party test some of their children’s products in order to certify compliance with one particular group of children’s product safety rules. In this case, qualifying small batch manufacturers that are registered with the CPSC may not need to third-party test their products for compliance with the limits on total lead content in the garment and for phthalates in the types of garments discussed above.

However, all children’s products still must comply with the underlying regulations and all registered small batch manufacturers must still issue a CPC.

More information on third-party testing requirements for small-batch manufacturers is available at
Note: This article does not, and is not intended to, constitute legal advice. It has not been reviewed or approved by the Commission and does not necessarily represent their views. Any views expressed in this communication may be changed or superseded by the Commission. 

(31) Comments

muneerahmed400's picture

Wow, this article is really very good, so that I can't say how happy feeling. The article make every detail of the story depicts streaming with the best, and every movement of the characters all write so lifelike, let me see the waves excited.Calculatoare Second Hand

mylink1257's picture

I am exploring this topic for a report I have to write. You have good content and I would like to know if you have any other posts about this? portable washing machine

michealjohn001111's picture

Really great post. I simply unearthed your site and needed to say that I have truly appreciated perusing your blog entries. Any way I'll be subscribing to your food and I trust you post again soon.
recruitment agency gta

michealjohn001111's picture

Thanks for writing such a good article, I stumbled onto your blog and read a few post. I like your style of writing...
Injustice Hack

mylink1257's picture

I am very happy to read this. This is the kind of manual that needs to be given and not the random misinformation t hat's at the other blogs. Appreciate your sharing this best posting.
Handy home cleaning

mylink1257's picture

Kids martial arts classes Palm Beach Gardens Hello! I just wish to give an enormous thumbs up for the nice info you've got right here on this post. I will probably be coming back to your weblog for more soon. karate schools in Palm Beach Gardens

muneerahmed400's picture

This is a wonderful article, Given so much info in it, These type of articles keeps the users interest in the website, and keep on sharing more ... good luck. bubblegum casting

michealjohn001111's picture

I have recently started a blog, the info you provide on this site has helped me greatly. Thanks  for all of your time & work.

mylink1257's picture

Very informative post! There is a lot of information here that can help any business get started with a successful social networking campaign!
Kids karate Palm Beach Gardens

khansaleem952's picture

I really like the dear information you offer in your articles. I’m able to bookmark your site and show the kids check out up here generally.

bubblegum casting

handsomemanhandsomeman001's picture

I feel a lot more people need to read this, very good info! . . . . . .

mylink1257's picture

It is very well written and obviously you know a lot about the subject I even suspect that you haven’t said all you know.
SEO Company

handsomemanhandsomeman001's picture

Thanks for providing recent updates regarding the concern, I look forward to read more
Hypnosis MP3

handsomemanhandsomeman001's picture

Took me interval to predict many the statements, however I truly loved the paper. It proved to be Truly useful to me similarly I am inevitable to total the commenter here! It’s always pleasing whereas you can hardly singular be knowing, however also entertained!
coach luke fitness pro

handsomemanhandsomeman001's picture

Actually I read it yesterday but I had some thoughts about it and today I wanted to read it again because it is very well written.
spiritual life coach

handsomemanhandsomeman001's picture

Easily, the article is actually the best topic on this registry related issue. I fit in with your conclusions and will eagerly look forward to your next updates. Just saying thanks will not just be sufficient, for the fantasti c lucidity in your writing. I will instantly grab your rss feed to stay informed of any updates.
prostate massage

handsomemanhandsomeman001's picture

Hey – great blog, just looking around some blogs, seems a really nice platform you are using. I’m currently using WordPress for a few of my blogs but looking to change one of them over to a platform similar to yours as a trial run. Anything in particular you would recommend about it?
visit this site

michealjohn001111's picture

"This is just the information I am finding everywhere. Thanks for your blog, I just subscribe your blog. This is a nice blog. "

harrypoter459's picture

On je sposoben pokazati resnico življenja, tako rekoč, na drugi strani pa je lahko neusmiljeno zasmehovanje in nepristranske človekovih pomanjkljivosti. Piše zelo jedrnato in spretno. Vedel je, življenje in ljudi. V kratki zgodbi lahko odpre cel svet, svet duše, prostor v notranjosti človeka. Na primer, zgodba "Student", se zdi - majhen dve strani zgodbe o tem, kaj lahko rečem? O veliko stvari: o človek išče pot svojega življenja tava v temi, vendar pa kaže, da svetlobo, in po tem, ko ga je pridobil vero našel - secira obzorju linijo zore. - Simbolistično, videnje iskro v vsakem človeku. Zato sem ga ljubim.
cheap custom essays

michealjohn001111's picture

Actually your experimental writing capacities has motivated me to begin my own particular Blogengine blog now. Truly the blogging is spreading its wings quickly. Your compose up is a fine illustration of it.
schools driving lessons new york

michealjohn001111's picture

So luck to come across your excellent blog. Your blog brings me a great deal of fun.. Good luck with the site.
writing papers

michealjohn001111's picture

I agree with your blog and i will be back to check it more in the future so please keep up your work. michael kors outleti love your content & the way that you write.
cheap air max 1

michealjohn001111's picture

You have done a great job. I will definitely dig it and personally recommend to my friends. I am confident they will be benefited from this site.
small business taxes

michealjohn001111's picture

Really great post, Thank you for sharing This knowledge.Excellently written article, if only all bloggers offered the same level of content as you, the internet would be a much better place. Please keep it up!
Fifa 15 Hack

allanmurray20's picture

Love the design and the decor. Such an awesome blog to share and read some comments. By the way, here is my site - Exterminator Manhattan NY

kevins.peterz's picture

Beautification Guides is probably the finest guides of which provide help to beautify your favorite places and also points. Throughout easy terms by using adorning e-book you can beautify your own home, back garden, company, cakes, snacks, for example. They have the most effective selection within the vast majority of subjects that the designer searches for pertaining to. Together with adorning e-book you can make some sort of well-decorated production. This doesn't happen issues no matter whether you are a fantastic designer as well as not necessarily although with an suitable adorning e-book you can beautify quickly and also swiftly.
research paper writing help

michealjohn001111's picture

Hmm… I read writes on a comparative subject, however i never went by your online journal. I added it to top choices and i'll be your steady followers.
inflatables rhode island

handsomemanhandsomeman001's picture

You are allowed to post names, but not links, unless they are approved and on topic.

handsomemanhandsomeman001's picture

My professor always yields complaisance to grammar guides of my college research paper also different missions. That's reason I recognize that it isn't familiar project to indite an lovely paper. In your case text is positive further fascinating.

mi5data's picture an extortion racket law.
Compare the fact humans have been able to make their own food, clothing, shelter for thousands of years, and now these people have authority over how you operate your business.

Wise up sheeple.
This is not Animal Farm the book, this IS the Animal Farm.

Leave a Comment

Premium Subscription

Please sign in to leave a comment

Click here to Sign in. Don't have an account? Join Today (It's Free!)