focus on apparel decoration

8/11/2019 Focus on Apparel Decoration

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Focus On Apparel Decoration

Susan DeRagon and Haley WillUL / PPAI Product Safety Consultants


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This information is being furnished by PPAI for educationaland informational purposes only. The Association makes no

warranties or representations about specific dates,

coverage or application. Consult with appropriate legalcounsel about the specific application of the law to your

business and products.


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Agenda

Federal Regulations for Apparel Decoration

- Children's Apparel

- Child-care Articles

Assuring Ink Compliance Tracking Labels

Best Practices

Recordkeeping


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Childrens Apparel Defined

Infant and youth size garments


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Federal Regulations for

Childrens Apparel

CPSIA, Section 101 - Childrens Products Containing Lead

100 ppm limit

Applicable if the ink becomes part of the garment Compositing and component testing allowed


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Childrens Apparel

CPSIA, Section 101 - Lead Paint Rule

90 ppm limit

Applicable if the ink can be scraped off the garment

Composite and component testing allowed

HDXRF or wet chemistry


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Childrens Apparel

Any hard attachments?

Both lead limits apply to the decoration

Use and abuse testing for attachments is recommended(small parts, sharp points, sharp edges)


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Child Care Articles

CPSIA, Section 101 - Childrens Products Containing Lead

CPSIA, Section 101 - Lead Paint Rule

Any hard attachments?- Both lead limits apply to decoration

- Use and abuse testing for attachments is recommended(small parts, sharp points, sharp edges)


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Child Care Articles

CPSIA, Section 108Products Containing Certain Phthalates

0.1% limit

Permanent Ban: DEHP, DBP, BBP in any amount greater than 0.1 %

Interim Ban: DINP, DIDP, DnOP in any amount greater than 0.1 %

Interim banned phthalates limits apply to toys and child care articlesthat can be placed in a childs mouth whereas the permanent banapplies to any toy or child care article

Composite and component testing allowed

Likely to be found in decoration or attachments such as Velcro, vinyl,zippers, buttons, clasps, and rhinestones.

Inaccessible component parts are exempt


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Mandatory Third Party Testing for

Certain Children's Products

Third party testing currently required for:

- CPSIA, Section 101Childrens Products Containing Lead

- CPSIA, Section 101Lead Paint Rule

- CPSIA, Section 108Products Containing CertainPhthalates

Laboratory must be CPSC approved and accredited

Testing frequency prescribed by the Testing and LabelingPertaining to Product Certification Rule


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Certification

Importer or Domestic manufacturer is responsible for testingand certification

All testing must be reflected in Childrens Product Certificate(CPC) or General Conformity Certificate (GCC)

Must be produced and made available for every youth order


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Requirements for Certificates

1. Identification of the product covered by this Certificate2. Citation to each CPSC product safety regulation to which

this product is being certified

3. Identification of the US importer, if applicable, or domestic(US) manufacturer certifying compliance of the product

4. Contact information for the individual maintaining records oftest results

5. Date and place where this product was manufactured

6. Date and place where this product was tested for

compliance with the regulation(s) cited above7. Identification of any third-party laboratory on whose testingthe certificate depends


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Small Batch Manufacturers Registry

Small batch manufacturers are defined as those who:- Earned $1 million or less in total gross revenues from sales of

all consumer products in the prior calendar year, and- Produced in total no more than 7,500 units of at least one

consumer product in the prior calendar year

Registry was launched on December 23, 2011 through theBusiness Portal of SaferProducts.gov

Qualifying small batch manufacturers are exempted from certain

third party tests; however

ALL PRODUCTS MUST COMPLY WITH ALL MANDATORYSTANDARDS


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Assuring Ink Compliance

Have all your inks tested

Rely on ink suppliers tests and component testing rule

Perform third-party tests on finished product


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CPSIA, Section 103 - Tracking Labels

Required for all childrens products manufactured after

August 14, 2009

Enhance recall effectiveness

Required information:- Manufacturer name

- Month & year of manufacture

- City & state of manufacture

- Batch or internal order number- Distributor PO number


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CPSIA, Section 103 - Tracking Labels

Specifications:

Must be permanent

Hangtags and adhesive labels notacceptable


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Secondary Tracking Label

When a distributor sources from an apparel distributor,contracts with a third-party decorator to apply ink or threadto a garment, and sells the product, the garment has been

altered and requires a second tracking labelfor thesame purpose as the first


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Required Information:

Decorators name

Month & year decoration was applied

City & state where decoration was applied

Decorators batch or internal order number

Distributors PO number


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Best Practices

Label Location:

Bottom hemline

Inside back neck

Sewn in as a label behind the original care/trackinglabel


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Disclaimer goes here


Best Practices

PPAI Tracking Label Solution

Free to UPIC subscribers

Allows for short URL to satisfy requirements

Example:

http://ps.ppai.org/SAMPLE01


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Best Practices

Distributors, ask your buyer

1. Who is the intended audience?Will this item be distributed tochildren?

2. How will the products be distributed?

3. What kind of logo do you intend to use?

4. Do you typically keep items in stock for future use or do youdistribute all items?

5. Do the customers preferred products have child-like appeal orplayful elements? Or do those products have diminishing

appeal to the 12 and under crowd?


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Best Practices

Distributors, tell your supplier and decorator

The intended audience: If the item will be given to children

The distribution method The product you want


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Recordkeeping

Manufacturer must maintain the following records: Copy of Childrens Product Certificate for each product

Records of each third party certification test

- Separate CPCs and test records required for each manufacturing site

Records of appropriate periodic tests

- Periodic test plan and periodic test results

- Production testing plan, production test results, periodic test results

- Testing results of tests conducted by ISO 17025 testing lab andperiodic test results

Descriptions of all material changes, and the Certification tests related to

these changes Records of undue influence procedures, including training materials and

training records/attestations


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Recordkeeping

Records must be maintained for 5 years, and made availableto CPSC upon request

Records may be maintained in languages other than English

if they can be provided immediately to CPSC and translatedaccurately into English by the manufacturer within 48 hoursof a request


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Test Requirements for Common

Decorating Methods

Applique: Decoration or trimming cut from one piece of fabric andstitched to another to add dimension for design techniques

Testing Required: Total Lead Content (may be exempt if untreated

textile)

Backing: Material used beneath the embroidered fabric to providestability and support

Testing Required:Total Lead Content (may be exempt if untreatedtextile)


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Decorating Methods

Digital Printing: 4-color process of printing directly from a computerfile onto a garment

Testing Required: Total Lead in Paint (may be exempt if only CMYKprocess printing inks are used); Phthalates if childcare article

Debossing:A process in which fabrics are engraved with the use ofheat rollers under pressure to produce a concave/sunken design onthe fabric surface

Testing Required: Total Lead Content


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Decorating Methods

Embossing:A process in which fabrics are engraved with the use ofheated rollers under pressure to produce a raised design on the fabricsurface


Embroidery:Decoration consisting of needlework created using aspecial machine that is programmed to stitch a design combining

texture, pattern and colorTesting Required: Total Lead Content (may be exempt if untreatedtextile)


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Decorating Methods

Flocked Transfer: Very short individual colored fibers are adhered toa transfer sheet to create intricate textured designs that are transferredto a garment using heat


textile)

Heat Transfer:The process of transferring a design from a speciallytreated paper to a garment using temperatures around 375 degrees F(190 C).

Testing Required: Total Lead Content (subject to Lead in Paint, ifscrapable); Phthalates would be applicable if scrapable design anditem is a childcare article.


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Decorating Methods

Laser Applique: A laser beam is used to cut single or multiple fabriclayers revealing a fine, detailed design


textile fiber)

Laser Etching: A process that uses laser technology to etch or burn amark on a fabric surface

Testing Required: Total Lead Content (may be exempt if untreatedtextile)


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Decorating Methods

Screen Printing: The process of printing by squeezing ink throughscreens allowing colors to pass through open areas to create a design;Multi-colored designs are achieved using one screen for each color inthe design

Testing Required: Total Lead in Paint; Some screen printing

penetrates fabric such that is not scrapable and then Total LeadContent testing would be applicable; Phthalates if screen printing isscrapable and item is a childcare article

Printed Transfer: Printed transfer uses many of the same inks andtechniques of printing to create a design that is transferred from asheet to a garment using heat

Testing Required: Total Lead in Paint; Phthalates if childcare article


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Decorating Methods

Sequin Embroidery: A technique in which sequins are embroidereddirectly onto a substrate

Testing Required: Total Lead Content; Total Lead in Paint, if sequinsare painted; Phthalates if sequins are painted and item is a childcare

article.

Specialty Threads: Threads designed for effects such as shine,glitter, iridescence or thickness; The threads are often made fromsynthetic materials including rayon, mercerized cotton, metallic andtextured nylon



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Decorating Methods

Studded Transfer: Colored metallic and rhinestone studs are arranged on asheet that is used to transfer the studs to a garment using heat

Testing Required: Total Lead Content; Total Lead in Paint, if studs are painted;Phthalates if studs are painted and item is a childcare article.

Sublimation: A type of transfer in which dyes, rather than inks, are used totransfer a design onto a substrate with a combination of heat and pressure; Thedyes vaporize and are absorbed by polyester fibers; The process can be usedto print textiles, as well as mugs, plates, or other specialty items

Testing Required: Total Lead Content; Testing may be exempt per below from

CPSC website.

Certain specialty textile ink systems may use inks that effectively act like dyes.

Those inks are absorbed into the fabric and bond with the fabric substrate,

effectively acting like a dye.


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Resources

PPAI: www.ppai.org

Product Safety powered by PPAI: www.ppai.org/productsafety

Consumer Product Safety Commission (CPSC): www.cpsc.gov

UL Consumer Products: www.ul.com or [email protected]

Questions?:[email protected]


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