Playing By the Rules

Compliance is a difficult subject. It's hard to memorize all of the rules. General use products have an extensive list of requirements and children's products have even more, but what about when a general use product becomes a children's product? We spoke to three industry suppliers to gather a few tips on what to look out for when potentially transforming bags, writing instruments or drinkware into a children's item.

Bags

Shopping bags and totes are general use items, but alterations, such as a adding a child-friendly logo, reducing the size, or offering it in a bright color, among other things, could make it a children's product, as is the case with any general use product.

"Occasionally, we'll import custom [children's] bags/backpacks from China. For those types of items, we check to make sure no drawstrings and small parts are used, and they are tested for CPSIA [Consumer Product Safety Improvement Act] compliance," Angela John, director of regulatory compliance and product safety for Sun Coast Merchandise, Commerce, Calif., said, warning that although drawstrings are not regulated on children's bags as they are in apparel, they should be avoided.

Since imprints are a common way general use items cross over and become children's items, Sun Coast puts in extra care to meet compliance requirements when a children's logo is requested. "When we do come across a logo that's incredibly child-friendly, we have trained our customer representatives to elevate that order to the compliance department," John said.

However, the biggest concern in bags is with the PVC coating, which often contains phthalates and is applied to the inside of a bag to make the fabric sturdier. According to CPSIA, three phthalate types (DEHP, DBP and BBP) are banned, while three other variations (DINP, DIDP and DnOP) are regulated at 1,000 ppm per phthalate. "Within the industry, there is a lot more effort to switch out of PVC completely, but because of the price point, it is something that suppliers tend to use a lot," she said. "However, PVC is a highly susceptible for phthalates (regulated by CPSIA) so we tend to avoid PVC in children's products and suggest alternatives to our customers due to the high risk."