I'm curious if any BGDF self-publishers have fully digested and understand what will be required administratively and monetarily to comply with the testing requirements for game products marketed and labeled for ages 8 to adult? This just seems like an unresolved and fluid matter at the moment and another publication hurdle at first sight...any thoughts or comments?
An Amendment to the Consumer Product Safety Improvement Act (CPSIA)
Sample text quotation:
The CPSC will take into account economic or other limitations that “small batch manufacturers” may face in third party testing and provide alternative testing requirements for "covered products." If the CPSC determines that no alternative testing requirements are available or economically practicable, the CPSC will exempt small batch manufacturers from the testing requirements. The CPSC may also allow small batch manufacturers to certify products based on documentation that the product complies with another national or international governmental standard or safety requirement. The CPSC may not require third party testing for small batch manufacturers until the CPSC has provided alternative requirements or an exemption. Small batch manufacturers must register with the CPSC before using any alternative testing requirement or exemption.
[“Small Batch Manufacturer” is defined as a manufacturer that has no more than $1,000,000 in total gross revenue from sales in the previous calendar year adjusted annually by the percentage increase in the Consumer Price Index for all urban consumers published by the Department of Labor. Total gross revenue includes all gross revenue from all sales in all consumer products of each entity that the manufacturer controls. Such provisions do not apply to manufacturers of defined durable juvenile products under existing CPSIA Section 104.
“Covered product” is defined as any consumer product manufactured by a small batch manufacturer where there are no more than 10,000 units of the same product manufactured in the previous calendar year.]
I plan on making some phone calls at some point in attempt to clarify some of the compliance hurdles that hinder the way of publication. Please share your comments if you can help clarify the compliance issues as well...
Some things I'll try to clarify are:
Will a sample game from each small batch production need to be tested...as I recall this was the case...and what exceptions might there be?
As I recall, books appear to have an exemption...what about rule sheets, game boards, playing cards...etc...why are they different?
Why would we even need to bother with this testing if small batch products were made in the USA from a qualified source (which is where the compliance should originate)?
It is troubling to think that if we overlook something and are out of compliance...that we would end up with product that could not be sold in any marketplace... other than lawyers...how do you best stay informed?
Would like to know more about the CE certification process as well...please share your comments...