Dear Chairman Upton and Chairwoman Bono Mack:
Thank you for your continued attention to the needs of the small business members of the Handmade Toy Alliance, (HTA). Our purpose from the beginning of our organization has always been to mitigate the costs of CPSIA mandated third party testing and to remedy the unintended consequences of the CPSIA that fall disproportionately on small batch children's product manufacturers, retailers, and importers. The preferred solution remains a legislative exemption for these small and micro-businesses.
Although H.R.1939 allows relief for our members in the area of third party testing, we remain concerned about other provisions of the CPSIA which unfairly disadvantage small businesses. These include retroactivity, labeling requirements, the 100ppm lead content standard, and lack of harmonization with the European Union. In the interest of expediency, we have chosen to focus our efforts on providing the most relief for as many of our members as possible.
In surveying our members, our analysis is that the greatest burdens we face are mandatory third party testing for lead in substrate and ASTM F-963 testing for toys, both of which are scheduled to be implemented by the end of this year. H.R.1939 proposes third party testing relief to the members of the HTA through CPSC rulemaking to specify an alternative test or exemption, with the protecting stipulations that the benefits of third party testing justify the costs and that rules impose the least possible burden. This language within H.R.1939 makes compliance more achievable for our membership and for that reason we endorse this bill.
Legislative proposals offered in the last Congress failed to go far enough in providing relief for our small business members. H.R.1939 is closer to meeting the needs of our membership. It is imperative that both the House and the Senate take action without delay to save what remains of the culture of handmade toys and children’s products in the USA.
We remain hopeful that the democratic process can prevail and that a meaningful and bipartisan reform of the CPSIA will be enacted. On behalf of the 647 small business members of the Handmade Toy Alliance, we thank you again for your attention to this important issue.
The Handmade Toy Alliance Board of Directors