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