Looking to Buy Products Made in the USA?

The Office of Textiles and Apparel at the US International Trade Administration has a handy portal to help sellers find vendors who manufacture products made in the USA.

Specific to the textiles and apparel industries, the portal allows you to search for vendors of children’s wear (including infants), men’s and boy’s, or women’s and girl’s apparel, in addition to accessories and footwear, technical textiles as well as soft furnishings.

You can further search by fabrics, whether of wool, cotton, upholstery, silk and other fabrics.

Whether searching for a cut and sew contractor, input supplier, manufacturer or other type of business, the information you will get back includes an entity’s contact information, whether or not they export, production capacity and production locations.

You can also learn if they have design capabilities, have any special washes or treatments available, certifications offered and many other details.

To go to the Made in USA search portal, click here.

Questions/comments?  Post below or email me at fashioncompliance@gmail.com

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International Trade and Human Rights

PBS aired a news piece recently that spoke to the human rights abuses in textiles factories in Cambodia. 

How do human rights abuses affect international trade?

 Maltreatment of apparel workers in the developing world as well as here in the US is common practice and has been for decades. 

How do we as a country that prides itself on labor laws and OSHA regulations (the "healthy workplace" standards in the US) so easily ignore this reality when we as consumers can have a direct impact in trade and overseas production if we speak with our wallets?

Doesn’t money talk?

Indeed it does, as many licensors know who place manufacturing requirements in its contracts with importers in an attempt to improve the working conditions of overseas laborers.  (See my article here for more information.)

Many importers of both unfinished and finished products, as well as agribusiness, see Africa as the “new frontier”. 

What I would like to know is:  Will we do it the “right way?”

That is, in a place with loose regulations (at best) will we – those of us going into the many countries that make up Africa – take advantage of the people and their land?

Or, will we create a business environment where human life and dignity are respected and sustainable production is expected, such that the health and welfare of both the people and the environment are respected?

In my view, the latter is the only answer, not only from an ethical standpoint but from that of a sustainable business model. 

Questions/comments?  Post below or email me at clark.deanna@gmail.com

CPSC Signals That Flammability and Lead Risks Related to Children’s Sleepwear a Priority Issue for 2012

In a letter to importers, manufacturers, retailers and distributors of children’s sleepwear and loungewear late last year, the Consumer Products Safety Commission (CPSC) sent a reminder of its enforcement policy as it relates to risks of burn injuries and chemical contamination.

Children’s sleepwear standards were developed to prevent children’s sleepwear from igniting due to exposure to ignition sources, such as candles, ranges, stoves, matches/lighters, space heaters and fireplaces. Most of the ignition incidents were found to occur while children were wearing sleepwear or sleep-related items during the evening before bedtime or in the morning around breakfast time.

In addition to burn prevention, contamination by way of lead exposure was also signaled as a priority issue as this letter included a summary of the Consumer Product Safety Improvement Act of 2008 (CPSIA) requirements which include the usage of tracking labels, a certificate of compliance and testing requirements for phthalates, lead content and lead in surface coatings on snaps, zipper pulls and elsewhere on the product.

CPSC is charged with protecting the public from unreasonable risks of injury or death associated with the use of the thousands of consumer products under the agency's jurisdiction.

Included in its jurisdiction is the oversight and enforcement of the Flammable Fabrics Act, which includes protecting the public from the hazards of flammable fabrics, interior furnishings and wearing apparel, including children’s sleepwear.

“Children’s sleepwear” includes any product of wearing apparel (in sizes 0–14), such as nightgowns, pajamas, or similar or related items, such as robes, intended to be worn primarily for sleeping or activities related to sleeping. Exemptions to this definition include: (1) diapers and underwear; (2) “infant garments,” sized for a child nine months of age or younger; and (3) “tight-fitting garments” that meet specific maximum dimensions.

Children’s sleepwear includes “loungewear” as a type of children’s sleepwear which was introduced to the children’s market in the 1990s. CPSC considers children’s “loungewear,” or other similar garments marketed as comfort wear, as garments worn primarily for sleep-related activities. Therefore, “loungewear” must comply with the children’s sleepwear standards as well.

For more information on some of the related regulations, click here.

Questions/comments? Post below or email me at clark.deanna@gmail.com

Toxic Purses?

Earlier this week I saw a news piece on Headline News about toxics in handbags. It mentioned how over time as you get to love your handbag, i.e., the more it is worn, the greater the risk of releasing chemicals which were not on its surface thereby exposing yourself to them.

In an effort to reduce shopper concerns, retailers including Saks Fifth Ave., Target, TJMAXX, and many others, all agreed (according to Headline News) to not sell products with contaminants in them.

But how does a retailer actually prevent this? And given the nature of manufacturing in today’s modern world, how can exposure to toxics (which lie beneath the surface) over a certain amount of time be avoided?

At the federal level, the Consumer Product Safety Commission (CPSC) has regulations regarding maximum levels of certain chemicals, such as Lead and Pthalates in consumer products. CPSC has also found lead to not be naturally occurring in certain articles, like cotton.

On top of federal regulations, however, some states, like CA, have taken matters into their own hands when it comes to the protection of consumers. It has done this through a law that came out in the 1980s (and is gaining renewed momentum) called Proposition 65.

Proposition 65 requires businesses to warn people about significant amounts of chemicals in the products they make where that chemical is both (1) known to cause cancer, birth defects or other reproductive harm, and (2) is listed on the “Prop 65 List.”

California’s Prop 65 in its simplest terms, requires a label where a product contains a chemical compound that exceeds the Safe Harbor Level. Safe Harbor determinations are based on a person’s exposure to a chemical, assuming daily exposure at that level.

The warning to consumers is typically done via the placement of a “warning label” directly onto the merchandise itself.

Retailers and importers therefore, need to test their products (typically done at the production level) for the existence of these chemicals and, if found, are subject to the label requirement.

As for which parts to test, merchandise is subject to testing for all parts to which a user may come into contact with, or otherwise be exposed to. Therefore, all outer and inner surface materials require testing.

With all of the recent buzz around the existence of chemicals in consumer products, namely with lead, phthalates and cadmium, I decided to look into the Proposition 65 rules regarding these 3 chemicals.

While stated in simple terms, there are technically several subdivisions of each of these chemicals, only a handful of which are on the Prop 65 List and therefore, subject to testing. They are:

5 Listed Phthalates:

Di(2-ethylhexyl)phthalate) (DEHP)
Di-n-butyl phthalate (DBP)
Di-n-hexyl phthalate (DnHP)
Butyl benzyl phthalate (BBP)
Di-isodecyl phthalate (DIDP)

4 Types of Lead:

Lead
Lead acetate
Lead phosphate
Lead subacetate

1 Type of Cadmium

Cadmium

California’s Office of Environmental Health Hazard Assessment (OEHHA) provides a list of “Safe Harbor Levels,” of which there are 2 types (NSRLs and MADLs (defined below)). These levels are intended to assist in determining whether warnings are required on products for exposures to the listed chemicals because if those levels are exceeded, a label is required.

According to Susan Luong of the Prop 65 Office, however, they are not intended to provide a “maximum acceptable amount” of a chemical in a product (like how CPSCs regulations provide) because there is no established allowable concentration level for listed chemicals.

In my experience working with importers who want to be compliant with state and federal laws, having limits but declaring that they are not maximums is confusing. This is because in order to be compliant, there need to be straightforward rules so that those entities subject to penalties for not following them, understand what needs to be done and can add measures to their compliance programs as appropriate.

With more companies being the target of these laws due to greater consumer awareness, it is imperative that federal and state agencies give manufacturers, importers and retailers the information they need to be compliant.

NSRL ("No Significant Risk Levels" (NSRLs) for carcinogens)
MADL ("Maximum Allowable Dose Levels" (MADLs) for chemicals that cause reproductive toxicity)

Questions/comments? Post below or email me at clark.deanna@gmail.com