common questions and answers

BCIA – testing requirements and reporting

Retail Package -Part of the CFR is to review the packaging and all labelling on the packaging. If there is no retail package – IE sell online only – mark onthe test request form

Lab should only check for the required marking on the product .

This will avoid automatic failure per the standard.

If members does not check off ”retail package” claim when submitting sample and a failure is issued then a $ 50 report revision fee will be collected.

16 CFR 1228 and 1230 references 16 CFR 1110 a Certificate of Compliance

  • What is the Third party lab responsibility? .

third party testing labs issue COC, then manufacturer issue Children Product Certificate (CPC) by copy and pasted the content of COC in their own company letter head.

  • What is required and or accepted? – common questions
  • a) is a letter stating material is compliant acceptablewhen no report is provided under16 CFR 1110?

No, only official test report issued by CPSC approved laboratories will be acceptable to fulfil 16 CFR 1110 requirement.

  • b.) Would SGS issue a Full COC or a pass report to fulfil CFR reporting without the chemical testing.

No, only official test report issued by CPSC approved labs could be acceptable as document to review in lieu of testing. Letter from material mfr (BOM – Bill Of Materials and BOS bill Of Substances) will not be acceptable to issue test report.

  • c) if client does not want Chemistry or full testing – SGS would only issue the physical mechanical test and client can issue own CPC. It is mfg responsibility to have Back up for CPSIA.

It is OK if client doesn’t request chemical testing, and proof of Burdon for CPSIA chemical testing is on MFG/ seller. We can test for physical/ mechanical only, and we will issue COC for what we test only. Clients are responsible to issue CPC mentioned above.

d) Who is responsible to issue a Certificate of Compliance ,CoC,and who issues the Childrens Product Certificate, CPC.

COC will be issued by labs,

CPC is mfr responsibilityunder 16 CFR 1110 based on CPSC approved third party reports as back up

e) Are letters received from supplier’s proof of testing per CPSIA?

No, CPSIA requires a test report from a CPSC approved lab as Back up.

f) Can SGS test and report on what is requested.

Yes, SGS can test and report on what is requested and the COC will reflect “ as requested” on report.

g) We understand it is up to the MFG to fill out a Children’s product certificate and have all back up to provide the CPSIA within 24 hours should the CPSIA coming knocking and asking for back up.

The CPSC has the right to request Back up for a CPC and it is MFG who signed CPS to provide documentation from an approved CPSC lab the COC’s. CPSC can provide 15 days to investigate but CFR states MFG must hand over documentation in a timely manner.

h) If I only want Physical mechanical testing done what do I need to put on Test request form? – be sure to follow top if there is no package

Check off the test needed and in Special instructions – “Physical/ mechanical only”

I)What do the X mean on Price list?

The X = the mandatory tests for each market and region. IE for USA the ASTM and CFR are mandatory tests required by CPSIA. SGS can test to the complete protocols or what members are asking. (it is the MFG. responsibility to provide proof of compliance if asked)

J) How many samples are needed –

This is a big question:

Physical mechanical test = 1 sample

Claims – IE care label appearance = Machine wash/ Dryer safe are required by claim verification testing to have 3rd party testing and fiber content = 1 sample

Flammability – if not exempt material needs 1 sample

Chemistry lab – if requested needs 1 sample

That is 4 samples -

k) can we use 1 sample

Depends on how long member can wait for report and what testing is being requested. 1 sample will slow down reporting substantially.

L) How many samples are needed for Distribution to EU

EU testing requires additional 4 samples to complete all EU testing due to all tests are different methodology. EU testing is done in France and or China only.

m) Why do we need a separate sample for care instructions

For care instructions should bea new untested item, because the purpose is to see the impact of washing- if it already has been stretched, cut or have any other mechanical process before then the results are inaccurate-

n) Why are we being charged for Monofilament

the standards state at 5.10 Monofilament threads – Monofilament threads shall not be used. Member options are to provide proof the threads are not monofilament or the lab needs to provide a visual inspection to determine the threads are or are not monofilament. Note - If monofilament threads are found then item fails.

0)TPCH – Packaging testing – do we need to test for packaging

Members do not need to test for packaging – for any items required under the CPSIA and CFR – to move the process along faster – members can submit a letter stating DO NOT TEST ….. and the lab can follow as not tested.

Note you will only receive a test report and the CFR report will be mostly blank.

The lab needs instructions to per the CFR.