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CPSIA

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coco
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Hi!

Reading the DeLano blog I found this:

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The big story in 2009, however, will be the changes wrought by the Consumer Products Safety Information Act of 2008 (CPSIA). CPSIA requires major changes in certification and safety labeling for products intended for use by children ages 12 and under. DeLano is already fully compliant with the new laws, but expect a general scramble of activity in early 2009, as the law goes into full effect on February 10th - just before the NY Toy Fair.
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I intend to publish small runs of a few games here in SPAIN in order to sell them worldwide, and this includes USA.

Can anybody explain to me what the CPSIA is all about in plain words and what do I have to do with my products?

Thank you.

truekid games
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my understanding is that it's

my understanding is that it's primarily a lead paint check- IF your product is intended for use by kids 12 and under, AND you want to export it to the United States, AND it includes parts of certain types (anything that has paint on it, for instance), then you'll need to have some official testing/certification to go with it saying that it doesn't have too much bad stuff (lead) in it.

that's my understanding at least, i'm sure someone else could point you at a specific site with requirements.

coco
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certification

truekid games wrote:
...you'll need to have some official testing/certification to go with it saying that it doesn't have too much bad stuff (lead) in it.

This certification must be done in USA?

Thank you

InvisibleJon
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Ask your manufacturer for proof of certification.

coco wrote:
truekid games wrote:
...you'll need to have some official testing/certification to go with it saying that it doesn't have too much bad stuff (lead) in it.
This certification must be done in USA?
Disclaimer: I am not a lawyer, or an import/export specialist, or anything like that. I'm just some dude on the internet.

That said: If you're getting something manufactured abroad, like in Spain, Germany, or China, you can probably ask the manufacturer if they are "XYZ Certified". Since many places want to be able to export to the USA, they should be able to tell you, and prove to you, that they are certified.

You may also need to specify that your product is intended for sale in the USA. Some manufacturers produce items to meet the standards required for the strictest market the product will be sold in.

Best of luck!

gameprinter
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CPSIA and You

As the guy who put the stuff on the Delano web site, I suppose I should weigh in.

The product must have less than 100ppm lead content and no pthalates.

The product must be labeled with the manufacturer and country info, as well as date or lot code for tracking. "Manufacturer" is construed to mean the final assembler of the product by most people. Also, stickers are not allowed.

Testing can be done anywhere.

That said, the US government just decreed that it will suspend the testing requirements for one year (until Feb 10, 2009), but that ALL products (not just new ones) must still meet the lead and pthalate requirements.

THEORETICALLY, the manufacturer can provide certification if they establish a "reasonable" testing program. Of course, the law doesn't say what is reasonable. On the other hand, the law is very vague as well on whether or not every SKU needs to be tested or if batch testing is acceptable.

Long story short: Make sure your printer/manufacturer has their ducks in a row or you might end up with unsaleable product a year from now. You may or may not have to foot the bill for $1000 worth of product testing.

coco
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This includes

gameprinter wrote:

The product must have less than 100ppm lead content and no pthalates.

Hi, gameprinter. Good to see you again.

This includes plastic game pieces, pouches, zip bags and plastic boxes? Only printed stuff?

Thank you.

gameprinter
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What's covered?

coco wrote:
gameprinter wrote:

The product must have less than 100ppm lead content and no pthalates.

Hi, gameprinter. Good to see you again.

This includes plastic game pieces, pouches, zip bags and plastic boxes? Only printed stuff?

Thank you.

No "exposable part" may have more than 100 parts per million of lead or any pthalates. That applies to everything but the shrinkwrap (which is thrown away immediately after purchase, so not counted).

Most printed games will be in compliance with these limits. It is the labeling and testing that will bite you in the behind down the road. You might have a perfectly safe game, but you have to be able to provide some kind of cert (from the mfr or from a lab) that states that is safe. Sadly, existing MSDS sheets aren't enough in most cases.

coco
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Thank you,

Thank you, gameprinter.

Suprisingly a lot of publishers are not meeting these requirements yet.

Darkehorse
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Wow

This seems like it will kill the small publisher unless:

1) They label it for ages 13 and up.
-or-
2) Make sure they use a printer who already has done all of this testing and is certified.

I see the need for this (especially for products coming out of China) but it is unfortunate for the small publisher. I imagine the Lot stamping will be most costly since they won't allow stickers. (Or is this something a printer can do rather easily?)

-Darke

coco
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label it for ages 13 and up

Darkehorse wrote:
...label it for ages 13 and up.

Yes. Most of the games I will (hopefully) publish are designed for ages 6 and up, but I've considered this solution (only for USA costumers).

Do you think this is 'elegant'? This implies making 2 covers: The USA cover and the euro cover.

gameprinter
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Don't

coco wrote:
Darkehorse wrote:
...label it for ages 13 and up.

Yes. Most of the games I will (hopefully) publish are designed for ages 6 and up, but I've considered this solution (only for USA costumers).

Do you think this is 'elegant'? This implies making 2 covers: The USA cover and the euro cover.

Don't just label it that way if the game will be used frequently by kids under 12. I just spoke with one of the folks at GAMA about this (at their Toy Fair booth) and she says that there are provisions that prohibit this. I haven't read the full 150 pages of the law, but if that's true, it's cheaper to comply than circumvent if you face a nasty fine.

coco
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How hard

How hard is it to be an independent publisher!

:-(

gameprinter
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Too True

coco wrote:
How hard is it to be an independent publisher!

:-(

We should all move over to designing Roleplaying Games. Books have a general exemption. :)

Rob Bartel
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What about card games?

From what I understand, the law is primarily targeted at paints and plastics. As you say, books are exempt. Is there any clarity at this point surrounding other paper-and-ink products like purely card games?

All the best in your new gig, by the way!

coco
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General Certification of Conformity

The General Certification of Conformity described in the CPSIA page says:

Q. Who must issue the certificate?
A. Under the Commission's rule at http://www.cpsc.gov/businfo/frnotices/fr09/certification.pdf,
for products manufactured overseas, the certificate must be issued by the importer. For products produced domestically, the certificate must be issued by the U.S. manufacturer. Neither a foreign manufacturer nor a private labeler is required to issue a certificate. Neither need be identified on the certificate issued by the importer or domestic manufacturer.

----> 'Neither a foreign manufacturer nor a private labeler is required to issue a certificate'

I'm manufacturing my games in SPAIN (EUROPE) and then selling them to USA costumers via my web site. Do I have to issue this certificate?

Thank you.

Néstor

gameprinter
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Rob Bartel wrote:From what I

Rob Bartel wrote:
From what I understand, the law is primarily targeted at paints and plastics. As you say, books are exempt. Is there any clarity at this point surrounding other paper-and-ink products like purely card games?

All the best in your new gig, by the way!

Paper and ink products other than books are NOT exempt. Even card games are covered. That said, a paper product made in the US on US or Canadian paper with vegetable-based inks, should exceed the standards of the law quite easily. Make sure you dot the i's and cross the t's though, by labeling correctly and, if required to later on, get a lab cert on the game. The testing component has been suspended for one year until Feb 10, 2009, but if you don't label now, you may have a problem later as stickers are not acceptable labels.

(Oh, and thanks! We had a great debut at NY Toy Fair)

gameprinter
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coco wrote:The General

coco wrote:
The General Certification of Conformity described in the CPSIA page says:

Q. Who must issue the certificate?
A. Under the Commission's rule at http://www.cpsc.gov/businfo/frnotices/fr09/certification.pdf,
for products manufactured overseas, the certificate must be issued by the importer. For products produced domestically, the certificate must be issued by the U.S. manufacturer. Neither a foreign manufacturer nor a private labeler is required to issue a certificate. Neither need be identified on the certificate issued by the importer or domestic manufacturer.

----> 'Neither a foreign manufacturer nor a private labeler is required to issue a certificate'

I'm manufacturing my games in SPAIN (EUROPE) and then selling them to USA costumers via my web site. Do I have to issue this certificate?

Thank you.

Néstor

Ummm....YOU are the importer in that case. You will have to provide certification if asked. Hopefully, your Spanish manufacturer can provide Material Safety Data Sheets or something so you don't have to pay for testing.

That said, if you are selling in ones and twos to individuals, I don't know that this will apply to you all that much. It's just not a big deal. If you want to ship to retailers or distributors in the US, then it might become an issue, because they might ask for docs. Joe Consumer probably will not.

Rob Bartel
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CPSIA

gameprinter wrote:
Paper and ink products other than books are NOT exempt. Even card games are covered. That said, a paper product made in the US on US or Canadian paper with vegetable-based inks, should exceed the standards of the law quite easily. Make sure you dot the i's and cross the t's though, by labeling correctly and, if required to later on, get a lab cert on the game. The testing component has been suspended for one year until Feb 10, 2009, but if you don't label now, you may have a problem later as stickers are not acceptable labels.

Interesting and thanks for the update. As you say, exceeding the standards of the law should be relatively easy as should proper labeling. Obtaining lab certification and pulling together the necessary documentation and paperwork is where the costs and headaches are going to lie.

gameprinter
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Bingo

Rob Bartel wrote:
Obtaining lab certification and pulling together the necessary documentation and paperwork is where the costs and headaches are going to lie.

Bingo. Yes - this is what is causing all the grief. Any idiot can print a card/board game that complies - most inks have a lead ppm of way less than 100 and paper is around zero - but certifying that you comply is the huge headache part.

coco
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Certifying

Certifying a game here in Spain costs around 400€ ($500) which is 1 $ per copy for a 500 print run. A LOT.

truekid games
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i missed it, what's your new

i missed it, what's your new gig, gameprinter? did delano go down fully?

gameprinter
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My new gig

truekid games wrote:
i missed it, what's your new gig, gameprinter? did delano go down fully?

I'm at Imagigrafx (www.imagigrafx.com. The setup here is much like DeLano, with a few added capabilities. We can do UV in house, for instance.

DeLano has not closed up yet - but they are not handling most new orders. Hopefully, that will all be resolved in the next couple of weeks.

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