Hm, my sense is that this is not something more sinister, and I'm sure big business isn't happy about the expense of it either. Consider the many layers and millions that all businesses will have to pay out for items that don't even fall into the toy category such as bedding, books, learning materials and my understanding is that it covers anything that is deemed for use by all items for use of children under the age of 12. Imagine all components for *each* manufacturing run must be certified such as inks / paints, parts, packaging, cloths, binding agents, papers and stuffing materials... and all items which must be continually tested for each run of each product... and all this in an economy where most manufacturers are not themselves doing well.

It was created as a sweeping reaction albeit well intentioned, to the toxic contamination of children's toys a few years ago by government who are still laying down the groundwork and considering the implicatons of their general and blanket agreement. My understanding is that the framework of the legislation is being altered and fixed almost daily. I think as a common citizen it behoves us to ensure that all products are indeed safe for our children and we should be more careful to see of the scope of the many millions of products that this legislation covers. I worry about the individual homecrafter and I hope the government will amend some kind of reconciliation for them as there is nothing so grand as an item lovingly made by an individual, but please consider that perhaps a law trying to ensure the health of children is not some great corporate villans attempt to drive grandma out of business.

You're right, big businesses aren't happy either, they actually stand a lot more to lose (scroll down to "How the law disproportionately affects large firms") than small companies. Another issue few are willing to accept, is it is products made by individuals that are more dangerous statistically. Flying under the radar, their products often don't comply with EXISTING bans regarding choking hazards and flammability. I don't want to hurt anyone's feelings by direct linking but people have been sending me links of very dangerous products sold on etsy (baby carriers made out of tee shirts, not stable and pacifiers with lead crystals glued to them).

That said, I represent the largest organization on the web of small clothing designers. Most of my companies are one or two person outfits who are legit down to following FTC regs for RN numbers and existing bans. Most craft indie producers don't even know these regulations exist much less follow them. Just because you're a nice person and sincere crafter doesn't mean your products are safe. Fwiw, when I attended the Product Safety Council meeting in Washington DC on Dec 3rd, Cheryl Falvey (general counsel of the CPSC) made it clear she was aware of indie producers selling on Etsy and stated they would have to comply with the law too. This is a health and safety issue. The tiniest restaurant must comply with the same laws that large chain restaurants do.

I wouldn't say the framework of the legislation is changing almost daily. Some of the regulations are being re-explained and refined every couple of weeks. Much of this relates to information that should have been published well before now.

As professionals, we applaud laws and regulations that will weed out unsavory players in our midst, those that give the rest of us a black eye. The problem is how the regulations have been interpreted in accordance to the law. Testing is a huge problem. We can only use a 3rd party lab approved by the CPSC. There's only 15 in the US, prices of testing have skyrocketed. A colleague got a quote to test a telescope for $24,000! Since his gross sales on this item are only $32,000, he won't be selling anymore telescopes to schools. Likewise, the only manufacturer of microscope lightbulbs to schools, has said they are not going to be selling those anymore either. This is a ten cent bulb that children won't be touching but it won't pass the *draconian* regulations. So much for science education in the schools. There's more and it's much worse. These youtube videos explaining all of this are compelling.

Previously, we were permitted to use lab results provided by our vendors for products we bought from them. We aren't allowed to do this anymore. This means that every single manufacturer who buys an identical zipper from company x will have to have it tested themselves. Even worse, we have to test EACH SKU, not each input. See, typically a designer will use the same fabric in three or four styles. It makes sense to test just that fabric. Likewise, they'll use the same exact buttons or zippers in each style so it makes more sense to test components. The regulations forbid this! We have to test each SKU. This means that altho the inputs of ten styles are identical to each other, we'll have to test all ten styles in each colorway (usually three). We already have quotes. The average cost of testing a ten piece line in three colors is $30,000 -$40,000.

I realize people think "manufacturers" have lots of money so this is no big deal but MOST children's wear manufacturers are really tiny companies. 68% have fewer than 20 employees. They may only cut 100 units of a given style -at most. As such, $30,000 -$40,000 represents their total production budget! What this means to consumers is that of those of us who don't go broke, what products are left in the market will be much higher priced than what consumers are used to paying, maybe double in price. And this is for two reasons. One, our costs have doubled. Two, with so few producers having the means to pay for testing, a lot of people are going broke which means, a whole lot less competition in the marketplace. Come next fall, there won't be much to pick from so who ever is left standing can pretty much charge what they want. If anything, this law will create entire monopolies. Since they mostly produce commodities, I wouldn't expect anything cute or attractive. They don't have to make nice things, you pay for it or your kids go naked.

Last of all, it's just stupid. Some products are inherently lead free anyway. The people who always skirt the law will find a way to continue to while the feds go after the good guys. This law will put the very people we WANT to be in business -the 100% organic producers, dedicated to health and safety- out of business.