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HTA Letter to CPSC on Reducing Testing Costs

We have been pleased to read the recently released staff document titled Consideration of Opportunities to Reduce Third Party Testing Costs Consistent with Assuring the Compliance of Children’s Products and would like to take this opportunity to comment on the recommendations. As you know, the members of the Handmade Toy Alliance have been considerably affected by the requirements of third party test and the “Small Batch” provisions of H.R.2715 provide relief for only a portion of our membership. We appreciate the efforts of the staff and commissioners to work towards additional solutions to this problem. There is still much to be done to restore businesses and reestablish the prominence of handmade toys in the United States.

Our Priorities for Staff Recommendations
Listed below are those staff recommendations we feel most directly address the burdens still borne by the members of the Handmade Toy Alliance. Our comments follow each recommendation.

(1) Establish a List of Equivalent Tests to those in CPSC-Administered Children’s Product Safety Rules 
First, accept our thanks for considering this issue and the comments from our letter of January 9th, 2012. This has been and continues to be a significant issue for us especially in relation to importing small batch1 toys from second tier manufacturers within the European Union where these toys have already undergone testing for compliance to the European Union (EU) toy safety standard EN71. Just over 25% of our members are small specialty retailers and importers who depend on access to small batch children’s products that the EU considers safe but are excluded from the market in the USA because of the economic burden of duplicate tests.

Moving forward with this staff recommendation provides substantial opportunity to: reduce duplication of effort and testing cost, clarify equivalencies and differences between standards, and to provide a vital first step towards harmonization of children’s product safety standards. We stress that harmonization is  our eventual goal in this effort, and that with careful attention to the process; harmonization can be accomplished with no compromise to safety in children's products.

There is no doubt that the primary way to restore the flow of safe small batch children’s products from Europe is to reduce and eventually remove the economic burden the CPSIA imposes on these manufacturers. The benefits are many: reopening trade between the USA and the EU, providing opportunity for specialty toy shops to compete with the mass market retailers, and restoring the enriching variety of wooden and classic toys from Europe.

(2) Research the Feasibility of Developing a List of Materials Determined Not to Contain the Eight Heavy Elements Listed in ASTM F963-11
A primary method used by members of the Handmade Toy alliance to reduce the cost of compliance is the component part rule in combination with the list of products determined not to contain lead in 16 CFR Part 1500. The new requirement of ASTM F963-11 with limits placed on concentrations of other heavy metals is an excellent opportunity to extend the positive impact of the existing determinations.

As small batch toys often use natural materials, the reduction in testing cost here is important. Effort expended by CPSC staff to make these determinations is an investment worth making. For many small batch manufacturers who use natural materials that already receive a lead exemption, this additional determination is a useful course to pursue while at the same time not compromising safety.

(3) Investigate Adding Manufactured Woods to Lead Determinations List 
The determination that wood does not contain lead is frequently used by small batch manufacturers to reduce the cost of compliance with the CPSIA regulation. “Manufactured woods” or laminated woods are frequently used in small batch children’s products when any dimension of the product increases above 10 cm (like a wooden puzzle) or if the product includes a cavity (such as a shape sorting box or dollhouse). For larger wooden components, manufactured wood is more stable and thus safer than wide pieces of solid wood, which can crack or splinter over time. We are concerned that some manufacturers will substitute solid wood for components which should otherwise be made from plywood or MDF in order to reduce testing costs.

If an investigation concludes that indeed manufactured woods do not include lead (or other heavy metals from (2) above) then toy safety is not compromised. Adding manufactured woods to the determinations list allows small batch manufacturers to resume using this material while taking advantage of the component part rule. Including manufactured woods in a lead testing exemption helps pave the way for this category of wooden toys from the EU to re-enter the USA market.

(4) Investigate CPSC Acceptance of Other Accreditation Bodies to Accredit Testing Laboratories to ISO/IEC 17025:2005 
The Handmade Toy Alliance supports any effort to increase the number of testing bodies certified to test for CPSIA compliance - especially where this expands the reach within the EU to make a third party testing laboratory more accessible when that laboratory is already testing compliance with EN71.

(5) Define a Periodic Testing Option Based on Volume of Products Manufactured Rather than Solely on a Time Period
The Handmade Toy Alliance supports an effort to set the frequency of periodic tests for low volume manufacturers based on quantities rather than time. There is reason to believe that a small batch manufacturer that performs a third party test can experience an economic savings by performing fewer tests within a fixed period of time.

Current rules which set retesting frequencies based on time rather than the number of units produced overwhelmingly favor large manufacturers at the expense of smaller manufacturers. The amount of theoretical risk which accumulates between periodic testing of an unchanging product is directly related to the number of units produced, not to the amount of time which has passed. We urge the commission to restore the rule which allows manufacturers to retest every 10,000 units.

Additional Considerations 
In addition to the recommendations submitted by the staff of the CPSC noted above, we’d like to reiterate two items we submitted in response to the request from the CPSC to comment on budget priorities for fiscal year 2014. These suggestions also help to reduce the costs of compliance for our members and do so without compromising product safety.

Product Specific Guidance 
The CPSC should publish guidance for common types of handmade toys and children’s products on how the myriad of safety laws apply to each specific product type. This helps small businesses get started and to understand the minimum amount of effort required to meet safety standards. The CPSC can work with the Handmade Toy Alliance and other small business groups to identify common products.

Specific guidance can be presented as web pages, PDFs, or handbooks as these are all searchable media. Webcasts can be created to aid the user and answer common questions. Some suggested product types are:

• Infant and children’s clothes 
• Doll clothing 
• Wooden toys with no moving parts that are painted or finished 
• Wooden toys with moving parts like wheels and axles with or without coatings 
• Children’s jewelry 
• Stuffed or plush toys 
• Cloth dolls 
• Vinyl dolls 

Component Parts Certification and Registry 
For handmade toymakers and small batch manufacturers, the most direct and cost-effective way to make sure their products are compliant is to use only raw materials and supplies that have been appropriately tested and certified to be free of lead and other toxic substances. We suggest that the CPSC work with toymakers and their suppliers to help create access to and market demand for raw materials that meet the requirements of the lead, toxics and flammability standards of the CPSIA.

Ultimately this should lead to a Component Part Registry or Seal program for raw materials that have been tested and certified not to contain lead or other toxics. The small businesses and hand-crafters that make toys can then easily find supplies and raw materials that carry the seal and are thus safe to use in their products. Suggestions for materials on such a list include:

• Paints and finishes 
• Fabrics 
• Fabric accessories (snaps, fasteners, zippers) 
• Fasteners and glues 
• Beads and other embellishments 

Conclusion
The Handmade Toy Alliance greatly appreciates the efforts the CPSC has taken to accommodate our membership with respect to toy safety standards and third party testing. However it important to note that we are still on this journey and there continue to be opportunities where burdens can be reduced without compromising safety.

We truly support the suggestions recommended by your staff noted above as well as our additional considerations and believe these suggestions are valuable and worthwhile. Please consider their positive impact on small batch manufacturers during the briefing on September 19th, 2012.

We ask that you vote to approve the staff’s recommendations and direct staff to pursue the recommended opportunities to reduce third party testing burdens on October 3rd, 2012. Thank you for your time and consideration in this matter.

Respectfully,
Randall Hertzler
Vice President of Handmade Toy Alliance

HTA Letter on the CPSC's Agenda and Priorities for Fiscal Year 2014

June 13th , 2012

Office of the Secretary
United States Consumer Product Safety Commission
4330 East West Highway
Bethesda, MD 20814

Thank you for the opportunity to comment on the agenda and priorities for the CPSC in fiscal year 2014. As you know, the members of the Handmade Toy Alliance have been considerably affected by recent regulations from Congress and the CPSC. We appreciate the efforts the CPSC has made to educate our members during this transition. There is still much to be done to restore businesses and reestablish the prominence of handmade toys in the United States. We hope these comments can move us all closer to that position.

Gnome Dolls from Bella Luna Toys

Product Specific Guidance
The CPSC should publish basic guidance for common types of handmade toys and children’s products on how the myriad of safety laws applies to each specific product type. This helps a small business get started and to understand the minimum amount of effort required to meet safety standards. The CPSC can work with the Handmade Toy Alliance (HTA) and other small business groups to identify common products.

Specific guidance can be presented as web pages, PDFs, or handbooks as these are all searchable media. Webcasts can be created to aide the user and answer common questions.

 Some product types are:

• Infant and children’s clothes 
• Doll clothing 
• Wood toys with no moving parts that are painted or finished 
• Wood toys with moving parts like wheels and axles with or without coatings 
• Children’s jewelry 
• Stuffed or plush toys 
• Cloth dolls 
• Vinyl dolls 

Component Parts Certification and Registry 
For handmade toymakers and small batch manufacturers, the most direct and cost-effective way to make sure their products are compliant is to use only raw materials and supplies that have been appropriately tested and certified to be free of toxics. We suggest that the CPSC work with toymakers and their suppliers to help create easy access to and market demand for raw materials that meet the requirements of the lead, toxics and flammability standards of the CPSIA.

Ultimately this should lead to a Component Part Registry for raw materials that have been tested and certified not to contain lead or other toxics. The small businesses and hand-crafters that make toys can then easily find supplies and raw materials that are safe to use in their products.

Some type of materials that would be helpful to have on this registry:

• Paints and finishes 
• Fabric and fabric accessories (snaps, fasteners, zippers) 
• Fasteners and glues 
• Beads and other embellishments 

Harmonization of Standards 
The differences in toy safety standards in the US and Europe continues to suppress the supply of small batch toys from Europe to specialty retailers in the US. In many cases the differences in regulations are small and in some cases even insignificant. But the small differences create a large economic hurdle that must be cleared by completing multiple tests that are nearly redundant.

We suggest the CPSC work to identify and resolve discrepancies in the safety standards in a manner that helps to reduce the current extended testing costs. Reducing these costs lowers the economic hurdle and allows safe small batch toys from Europe to again be sold in the US.

Conclusion
The CPSC has shown an inclination for working with small business through creation of the Small Business Ombudsman office and through invites to hearings and requests for comments like this one. The HTA greatly appreciates this relationship that has developed over the last few years and the suggestions presented here are an effort to continue and strengthen the CPSC’s connection to small business. Thank you for your time and consideration in planning your budget requests for your fiscal year 2014.

Respectfully,

The Handmade Toy Alliance

A Call for Help for a Mary Newell, Our Fearless Treasurer and Longtime HTA Advocate

Mary Newell, HTA Treasurer and owner of Mary's Doft Dough

We write to you today to share some news and need for outreach for one of our Board members, Mary Newell. Many of you have gotten to know Mary over the last few years. As a founding member since January of 2009, Mary has been intricately involved in our groups’ efforts to amend the CPSIA. She has given a tireless amount of time, effort and energy to further our collective cause. Mary has traveled to Washington DC on our behalf, lobbying Congress and participating in workshops and conferences at the CPSC.

Last month, Mary’s husband John went in for a routine health examination and came out with a diagnosis of stage 4 esophageal cancer. John is also a hand crafted artist – with a thriving business hand creating guitar parts. To chronicle his journey and battle with cancer, he has a created a blog. John started chemotherapy this week and is not able to work consistently. In addition, Mary has not been able to devote as much time to her business as she is doing her best to support her husband through his treatment.

As many small business owners have experienced, this kind of medical emergency can be financially paralyzing. The HTA Board has already reached out to CERF – Craft Emergency Relief Fund, asking if there is anything they can do in the form of grants or other financial assistance. We also wanted to let you all know that John has set up a donation site for those who are able to send financial support. For those of you who are able and so compelled, any donation would be greatly appreciated by Mary and John. Prayers, positive energy and good wishes are also very much needed.

From all of us on the HTA Board, we greatly appreciate your help, understanding and support. We wish you all the best for the upcoming year.

HTA Presentation to the CPSC Roundable Discussion on Small Business Outreach, October 6, 2011

The Handmade Toy Alliance, (HTA) representsa broad swath of small and micro businesses involved in production, retailing and importing of specialty toys and children’s products. These businesses are the backbone of specialty children’s products culture in America. They are mothers crafting items for sale on etsy.com, they aresmall specialty toy shops in towns across America, they are small businesses producing small batch toys in the USA, and they are all entrepreneurs providing new and unique opportunities for safe play.

This diverse membership struggles with assembling, reading, interpreting, understanding and implementingthe Consumer Product Safety Improvement Act (CPSIA.) The smallest microbusinesses have the largest hurdle to jump, but even our small business members have a sizeable learning curve. I’ll summarize these issues along with suggested outreach opportunities for threebusiness categories within the HTA.

Micro and Small Businesses Manufacturers
Micro-businesses are those crafting and retailing toys and children’s products in very small batches, each in very narrow product types. These businesses are family or single owner businesses with no employees and they represent 61% of our membership.In addition to selling their products online in a marketplace like etsy.com, they retail their products at small craft shows throughout the country. These may be church fairs, county fairs and other artisan events where they sell directly to the public.

Small businesses are those producing children’s products in small batches, often with broader product types. They represent 7% of our membership.

The following factors combine to makecomprehensionof the law problematic:

1. Insufficient time to digest the thousands of pages of law and rulings.
2. Inability to interpret the laws and rulings for their specific products and circumstances.
3. No feasible access to legal representation to provide an interpretation the law.
4. Difficult to obtain documents required by the law – ASTM F963 – because of cost and limited availability.

These businesses need the law boiled down to the minimum required for compliance in their specific business implementation. This amounts to individual legal interpretations for each business for each product they produce. This is literally hundreds of thousands of applications of the law. (There are currently over half a million children’s items for sale at etsy.com alone.)

The HTA suggests flowcharts or other easy to use methods like web-based question-answer forms for providing requirements in a logical manner. The intelligence programmed into the flowchart or form sequence leads business owners through questions ultimately arriving at requirements for their product. Either technique mustprovide the user the following information:

1. What parts of the law are applicable,

2. What tests are required and whether the test must be performed by a 3rd party;

• what is the specific component that causes the test requirement,
• a list of certified testing laboratories.
  

3. What possibility there might be for component part certification,
4. How to apply the small batch rules from H.R.2715,
5. What are the labeling requirements,
6. What are the record keeping requirements,
7. What liabilities and penalties come into play,
8. And, what form a certificate must take.

Another tool the CPSC can provide is to publish lists of components to avoid when making one of a kind and crafted children’s items. For instance; metal beads, colors that have a greater risk of containing lead, hazardous fasteners, etc. This is an easy way to keep components that are more likely to pose a risk of injury or that likely cause test failure out of children’s products from the start.

For reaching these businesses, the Internet is the primary method. Micro businesses rarely attend trade shows and most of them are NOT members of a trade organization like the HTA.The largest of the small business manufacturers may attend a trade show like ABC Kids recently held in Kentucky.

Specialty Toy Retailers
The second category is small specialty toy retailers, both brick and mortar and internet based. These businesses provide a market for small batch children’s products and an alternative for consumers not interested in products mass produced in the Far East. They differentiate themselves from mass market retailers by offering unique small batch products, usually through a single retail outlet. These businesses represent 25% of our membership.

Technically, these retailers are not required to test and certify but are subject to some requirements of the law depending on how they acquire their product for sale. Without sorting through thousands of pages of law, they need to know:

1. What parts of the law they should be aware of when working with small batch suppliers,

2. What record keeping requirements affect them,
3. What responsibilities they have when acquiring product directly from a local small batch manufacturer,
4. What responsibilities they have when acquiring product directly from a foreign manufacturer,
5. And how they can ensure their inventory is safe and compliant.

The Internet is also a primary source of information for specialty toys retailers. Many of these retailers attend at least one trade show yearly, for instance ABC Kids or the International Toy Fair in New York. These small retailers are seldom members of the Toy Industry Association (TIA) but some may be members of the American Specialty Toy Retailing Association (ASTRA.)

Specialty Toy Importers
The final category is specialty toy importers and these businesses represent 5% of our membership. It is a small percentage, but a big component in the culture of specialty toys in America as these importers provide access to mainly small batch products from Europe.

For importers the CPSIA blurs the definition of manufacturer to include the importer. The law is not always clear in how this blurring occurs. They need to know:

1. How to determine if they are considered the manufacturer of record, especially when they hold no inventory or only facilitate transport from foreign manufacturer to domestic retailer,

2. What testing requirements apply when a product is already third party tested to a European standard,
3. What record keeping requirements affect them,
4. And how to apply the small batch rules from H.R.2715.
The primary source of information for specialty toy importers is the internet and a secondary source is an industry group like the Handmade Toy Alliance.

In General

It is important to note that small batch manufacturers are constantly under production, although certainly the fourth quarter is the busiest time of the year for all of our membership. Issuing request for comments, changes and requirements during these 3 months will often go unnoticed.

The CPSC already has a wealth of information available. Unfortunately it is not always easy to find and utilize. Perhaps it would be advantageous to create a Wiki where businesses can post questions and the CPSC can post an official response. The wiki can also incorporate existing FAQs and guidance documents. Over time this becomes a valuable, searchable knowledgebase.

About the Handmade Toy Alliance

The HTA was formed in 2009 as an ad hoc group of businesses that were adversely affected by the CPSIA. During these past few years we have worked to save our member businesses from the unintended consequences of the CPSIA. We have testified before House and Senate committees and lobbied our representatives and senators. This culminated in the passing of H.R.2715 in August of 2011 which has two provisions that are an outgrowth of our work. Unfortunately, H.R.2715 is not the legislative fix our group desired, but places the fate of all of our businesses in the hands of the Consumer Product Safety Commission.

We currently have nearly 700 members but no offices, no staff, no legal representation, a volunteer board of directors who donate time and resources to the cause, and very limited financial resources. Although we work hard to help our members understand the law and to disseminate information, we are in no way prepared to be the source or conduit of comprehensive compliance information to our members. The width and breadth of the products produced by our members is enormous and the need to interpret the law for all of these single cases beyond our capability.

Today we hope to communicate to the staff of the CPSC as an advocate for our members, the magnitude of this issue and the primary problems that need to be addressed for educating our membership. We appreciate this opportunity to voice these concerns and look forward to working together to implement suitable solutions.

Image from Michelle Sorensen.

HTA Letter to CPSC on Registration of Small Batch Manufacturers in the CPSIA Reform Law

August 19, 2011

Office of the Secretary
Consumer Product Safety Commission
Room 502
4330 East-West Highway,
Bethesda, Maryland, 20814

Dear Mr. Stevenson:

On behalf of the Handmade Toy Alliance, an alliance now numbering 670 toy stores, toymakers and children's product manufacturers from across the country who want to preserve unique handmade toys, clothes, and children's goods in the USA, we respectfully request your clarification and action in regards to the registration requirements for small batch manufacturers in the newly signed CPSIA reform law, H.R. 2715.

Congress has now expressed its clear intent to provide regulatory relief to the small businesses we represent. As you know, H.R. 2715 allows small batch manufacturers to assure compliance with applicable product safety laws through less expensive alternative testing methods and exempts them from testing altogether when no affordable alternative testing methods are identified by the Commission.

The Handmade Toy Alliance would like to be fully engaged with the CPSC as it interprets H.R. 2715. Our goal, as always, is to create a regulatory environment which protects both public health and the welfare of the small businesses we represent.

It has come to our attention that members of the Commission are interpreting H.R. 2715's requirement for small batch manufacturers to register with the CPSC as a technicality which requires the completion of an official registration process by the Commission before relief willbe provided. This interpretation is contrary to our understanding of the law and contrary to congressional intent as we understand it through dozens of conversations with bothRepublicans and Democrats in the House and Senate.

The text of the law reads:

Any small batch manufacturer that utilizes alternative requirements or an exemption...shall register with the Commission prior to using such alternative requirements or exemptions pursuant to any guidelines issued by the Commission to carry out this requirement.

The word any in this sentence makes it clear that a manufacturer's ability to register with the Commission is not predicated upon whether or not the Commission has issued guidelines for registration. If the word any were not present in the sentence, the meaning would be different. However, the inclusion of the word any makes it clear that small batch manufacturers may still register with the Commission even in the absence any official guidelines. It is our interpretation that, in the absence of any guidelines from the CPSC, a small batch manufacturer may register with the CPSC in any manner which the manufacturer deems appropriate.

Our interpretation is supported by the previous section of the law, which reads:

The Commission may not require third party testing of a covered product by a third party conformity assessment body until the Commission has provided either an alternative testing requirement or an exemption...

This sentence clearly states Congress's intent that, in the absence of any action by the CPSC, third party testing will not be required for covered products made by small batch manufacturers. Relief is not contingent upon the CPSC's ability to identify alternative testing methods. Nor should relief be made contingent upon the establishment of registration guidelines.

We therefore formally request the Commission to make an immediate finding of fact that relief for small batch manufacturers under H.R. 2715 is not contingent upon the promulgation of registration guidelines by the Commission.

Notwithstanding our position on this interpretation, we would like express our interest to help create a sensible registration process as soon as possible. Registration should be simple and straightforward for both the Commission and small batch manufactures. We agree with Senator Rockefeller, who spoke on the Senate floor:

The creation of a new public [sic] registry for small batch manufacturers...can be implemented without notice and comment or even a hearing. As such, the Commission should act to effectuate the new mandates of this bill in a most expeditious manner.

Senator Pryor then seconded this view:

I also share the Senator’s view that nothing in H.R. 2715 is intended to delay the Commission’s rulemaking with respect to third party testing and believe that the Commission should conclude its testing rulemakings in the next 2 months.

We agree with Senators Rockefeller and Pryor that 2 months is an appropriate timeline to complete registration guidelines. This will allow enough time for small batch manufacturers to register prior to the expiration of the ASTM F963 and lead in substrate testing stays of enforcement on December 31. If the registration process is not completed by October 31, 2011, there will not be enough time to notify small businesses before the expiration of these stays. As we have stated previously, the last two months of the year are the busiest season for our members. So, the earlier they can begin to register, the better.

Small batch manufacturer registration can and should be as simple as filling out a registration form or sending an email to a specified address at the CPSC. The Commission may also want to allow outsourcing of this task to trade associations or businesses who could collect and compile a database for the Commission. We would like to discuss alternatives with the Commission as soon as possible, as well as ways in which our organization can help publicize the registration process to our members.

Thank you again for taking the time to read and consider our comments.

Respectfully Submitted,

The Handmade Toy Alliance

Congress Passes CPSIA Relief for Small Businesses!

In the past three years, Handmade Toy Alliance members were quoted in hundreds of news articles, testified 5 times on Capitol Hill in both the House and Senate, met with 4 out of 5 of the CPSC commissioners, phoned in to dozens of conference calls, wrote dozens of letters to the CPSC and hundreds of letters to Congress, and brought together over 600 likeminded small businesses--all to reform the CPSIA, a one-size-fits-all law that was killing our businesses.

And, just when it seemed that the debt ceiling crisis was going to swallow Washington whole and prevent any chance of CPSIA reform for another legislative session, the balance suddenly tipped yesterday. Within 8 hours, both the House and the Senate passed a bipartisan bill that provides a meaningful way forward for our members. Only two members voted against it in the House and it passed unanimously in the Senate.

While we did not write this bill, we were able to significantly influence it's design through dozens of meetings with Republican and Democratic staffers. It's not a perfect solution to the many problems of the CPSIA, but it does offer the promise of meaningful relief for small batch manufacturers. Basically, the new law will require the CPSC to identify "alternative testing methods" which are economically practical for each product safety standard which would otherwise require third party testing. And, if the CPSC is unable to identify an economically feasible alternative for a given standard, it must exempt small batch manufacturers from the testing requirement. And, it gives the CPSC the flexibility to recognize other standards, like EN-71 in the Europen Union, which paves the way for the return of small batch products from Europe.

These new rules will apply to standards such as the 100ppm lead in substrate rule, the ASTM toy safety standard, and a variety of other standards which apply to many different types of children's products. Notably, it does not apply to the lead in paint standard, the small parts standard for products designed for children under age 3, the lead in metal jewelry standard, and standards that apply to pacifiers, cribs, and durable nursery equipment; those standards will still require third party testing as they do now.

What is a small batch manufacturer? Basically, it's a business or group of similarly-owned businesses that make less than $1 million in revenue per year (indexed for inflation) from the sale of consumer goods. And, in order to qualify for these alternative testing methods or exemptions, products cannot be made in quantities greater than 7,500 per year. Qualifying small businesses will also need to register with the CPSC.

What this means is that the CPSC must act to ensure that product safety certification is affordable for small businesses. How that plays out over the next few years is very much in question, however, and it will require the HTA and other groups to remain steadfast advocates for our members. The importance of the HTA and other trade organizations will only grow as a result of this new law.

If this law is to work for us, we need your continued support! The fight is far from over--it's just moved from Congress back to the CPSC. The HTA could use your support now, more than ever. If you aren't already a member, please join us now. The HTA has low cost and even free options for membership. Not only will we be working to make sure that this new version of CPSIA does what it needs to for small batch producers, we will continue to promote members and offer great cooperative marketing opportunities.

Donate to the HTA

Yesterday morning, our members were facing a drop dead date on December 31, 2011, when two important CPSC stays of enforcement on third party testing requirements were set to expire. Today, we now have a way forward that will stop the CPSIA's one-size-fits-all approach and will hopefully keep our family businesses alive. That is the victory in today's votes.

We did this together! Thank you!