CPSIA Reasonable Testing Program Guidance and Requirements

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Consumer Product Safety

Improvement Act

Reasonable Testing Program Guidance

and Requirements

DECEMBER 2013
http://www.ddsdiscounts.com/index.aspxhttp://www.rossstores.com/


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I. INTRODUCTION...................................................................................................... 1

II. OVERVIEW OF THE CPSIA TESTING AND CERTIFICATION

REQUIREMENTS ..................................................................................................... 2

A. Certification of Childrens Products ............................................................... 2

1. CPSC Final Rule on Testing and Certification of Childrens

Products, Including Periodic Testing.................................................. 2

B. Certification of Non-Childrens Products....................................................... 6

C. CPSC Rule on Product Certification Based on Testing Conducted by

Another Party Third Party Finished Product or Component Part

Testing ............................................................................................................ 6

1. General Requirements Reliance on Testing Done by AnotherParty.................................................................................................... 6

2. General Requirements Component Part Testing ............................. 7

3. Due Care ............................................................................................. 8

III.

VENDOR RESPONSIBILITIES................................................................................ 9

A. Vendor Requirements for Childrens Products............................................... 9

1. Requirements for Each of Your Manufacturing Facilities

Ross Childrens Product CPSIA Compliance Questionnaire ............. 9

2. Requirements for Each Childrens Product You Supply toRoss..................................................................................................... 9

B. Vendor Requirements for Non-Childrens Products .................................... 13

1. Ross Non-Childrens Product CPSIA Compliance

Questionnaire.................................................................................... 13

2.

Requirements for Each Non-Childrens Product You Supply toRoss................................................................................................... 13

C. Requirements for Use of Component Part Testing for All Products............ 14

IV. ROSSS ROLE AS THE IMPORTER OF RECORD.............................................. 15

A. Rosss Due Care Responsibility ................................................................... 15

1. Vendor Evaluation ............................................................................ 15

2. Product Assessment.......................................................................... 15

3. Rosss Determination........................................................................ 16

B.

Recordkeeping/Technical File ...................................................................... 16

APPENDIX A: ANNUAL ROSS CHILDRENS PRODUCT CPSIA COMPLIANCE

QUESTIONNAIRE................................................................................................ A-1

APPENDIX B: ANNUAL ROSS NON-CHILDRENS PRODUCT CPSIA COMPLIANCEQUESTIONNAIRE................................................................................................ B-1

APPENDIX C: ROSS PRODUCT COVER FORM .......................................................... C-1


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APPENDIX D: ROSS CHILDREN'S PRODUCT PERIODIC TESTING PROGRAM

FORM........................................................................................................................D-1

APPENDIX E: ROSS CHILDREN'S PRODUCT PERIODIC TESTING PROGRAM

FORM.........................................................................................................................E-1

APPENDIX F: ROSS CHILDRENS PRODUCT CERTIFICATE.......................................F-1

APPENDIXG: ROSS GENERAL CONFORMITY CERTIFICATE ..................................G-1

APPENDIX H: ROSS CHILDREN'S PRODUCT TESTING SAMPLE SIZE

FORM........................................................................................................................H-1

APPENDIX I: SAMPLE UNDUE INFLUENCE POLICY....................................................I-1

APPENDIX J: SAMPLE MATERIAL CHANGE LOG ........................................................J-1

APPENDIX K: PRODUCT SPECIFICATIONS FOR CPSC STANDARDS,

RULES, REGULATIONS, AND BANS ...................................................................K-1


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I. INTRODUCTION

Ross Stores, Inc. is comm itted to ensuring that products sold at Ross Dress for L ess and dds

DISCOUNTS stores (collectively Ross) are safe for their intended use, and comply with all

applicable standards, requirements, rules, and regulations. This Guidance Document is intendedto provide you with procedures you must follow in providing pr oducts subject to the Consumer

Product Safety Im provement Act (CPSIA) ru les regarding testing and certification of

consumer products when Ross is the importer of record.

Section II contains a summary explanation of the testing and certification process required by theCPSIA. This includes inform ation on two i mportant rules issued by the Consum er Product

Safety Commission (CPSC) in conjunction with the CPSIA:

(1)the Final R ule on testing a nd certification of children s products, including periodic

testing (16 CFR 1107), which goes into effect for products manufactured after February

8, 2013, and

(2)

the Final R ule on product certification base d on testing conducted by another party,including component part te sting, which has been in e ffect since December 2011 (16

CFR 1109).

Section III contains CPSIA compliance procedures Ross has developed for you and the products

you supply to Ross.

Section IV discusses Rosss role in the testing and cer tification process, explaining how Ross

will evaluate you and the products you supply.

The Guidance Document contains a num ber of appendices with helpful information for your

review and consideration.

This Guidance Document is not intended to be a com plete listing of CPSIA and other consumerproduct safety com pliance requirements that m ay apply to your products. You are required

under the term s and conditions that apply to e ach purchase order issued by Ross to provide

merchandise that is safe and fi t for the use for whi ch it was manufactured, free from materialswhich may be injurious to persons, and m anufactured, packaged, labeled, and distributed in

accordance with all federal, stat e, and local laws. You must independently en sure that yourproducts comply with all consum er product sa fety standards and requirem ents issued or

administered by the CPSC, as well as with the testing and certification requirements CPSC issues

under the CPSIA. Standards an d regulations regarding consum er products are continually

changing, and Ross expects each vendor to rem ain current on requirem ents that apply to itsproducts. Your failure to com ply with the pro cedures set forth in this document will result in

Rosss rejection of you r goods, as well as an y other actions that Ross deems necessary o r

appropriate.

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II. OVERVIEW OF THE CPSIA TESTING AND CERTIFICATION

REQUIREMENTS

The CPSIA creates a num ber of safety standards and require ments for consumer products.

CPSIA amends the existing Consum er Product Safety Act, and is im plemented throughregulations adopted by the C PSC. Section 102 of the CPSI A requires m anufacturers and

importers of record to certify that each of their products complies with each applicable consumer

product safety rule, ban, standard, regulation, or law administered by the CPSC.

A. Certification of Childrens Products

A Childrens Product Certificate ( CPC) must be based on third-party testing of the finished

product performed by a CPSC-accredited laboratory. The CPSIA defines a childrens product asone that is primarily designed or intended for children 12 year s of age and younger. A listing

of standards that requ ire a CPC based on CPSC -accredited, third party laboratory testing is

available at http://www.cpsc.gov/cgi-bin/labsearch/.

For childrens products manufactured on or before February 8, 2013, all CPCs must be based onfinished product tests performed by CPSC-accredited, third party testing labs. You must provide

the test report and the information required by the Reliance Rule (discussed more fully in Section

C.1below). A majority of the information required by the Reliance Rule should appear on your

certification test reports.

For childrens products m anufactured after Fe bruary 8, 2013, all CPCs must be ba sed on theCPSC Final Rule on testing and certification of childrens products, incl uding periodic testing

(16 CFR 1107).

1. CPSC Final Rule on Testing and Certification of Childrens Products,

Including Periodic Testing

The CPSC Final Rule on tes ting and certification of childrens products (the Testing Rule),

sets forth requirements regarding: (1) representative samples required for CPSC-accredited thirdparty testing; (2) corrective action for failed tests; (3) periodic retesting of childrens products;

(4) retesting due to material changes; (5) training to prevent undue influence on testing labs; and(6) recordkeeping and documentation.

These requirements apply to manufacturers and importers of record. The requirem ents apply to

each facility manufacturing the product, if the same product is produced in multiple factories.

More information on these requirem ents is available at

http://www.cpsc.gov/businfo/frnotices/fr12/certrepr.pdf.

a. Representative Samples

The Testing Rule requires testing on a sufficien t number of samples of the product to achieve a

high degree of assurance that th e tests accurate ly show th at the childrens product meets the

applicable requirements. A high degree of assurance means an evidence-based demonstrationof consistent performance of a product rega rding compliance based on knowledge of a product

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establishes a schedule and requirem ents for in-house testing of production runs at each

manufacturing site. This in-house testing does not need to be performed by a CPSC-accredited,third party lab, and it does not need to comply with test methods required by CPSIA.

For example, production testing for lead in su bstrates may employ XRF screenin g, while theperiodictesting will require full digestion testing by the CPSC-accredited, third party lab. The

one year minim al interval m ay be extended to three years if the manufacturer em ploys a

Production Testing Plan and performs testing with an in-house ISO-certified lab.

During any stage of the testing, if a product fails testing, the manufacturer must investigate andcorrect the failure not just retest for a passing result.

A Production Testing Plan must include the following information:

Identification of the tests to be conducted/measurements to be taken;

The intervals at which those tests or measurements will be taken;

The number of samples that will be tested; and

An explanation describing how these tech niques and tests provi de a high degreeof assurance of compliance with the applicable regulations.

iii. Material Changes

In connection with periodic testing, the Testing Rule also requires retesting and recertification by

a CPSC-accredited, third party testing lab if the product u ndergoes a m aterial change. Amaterial change is any change that a m anufacturer exercising due care knows, or should know,

could affect the products ability to com ply with all applicable safety standards. This can

include changes in design, producti on method, or materials. It may also include resum ption ofproduction without change in design, production m ethod, or m aterials, if, for example, other

products were manufactured with the same production equipment in the interim, and this interimproduction has the potential to affect the child rens products com pliance with a consum erproduct safety standard that requires third-party testing.

d. Undue Influence Policy and Training

In addition to es tablishing testing and certification procedures, the Testing Rule r equires eachmanufacturer to implement procedures to sa feguard against undue infl uence on a third-party

accredited lab. At a m inimum, the procedures must include a written policy statement and staff

training. Personnel interacting with testing labs must undergo this training. Each manufacturing

site requires a policy and training. Manufacturer s must maintain records of training for five

years. We have attached a sample undue influence policy at Appendix F.

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e. Recordkeeping and Documentation

The Testing Rule requ ires manufacturers and importers of record to o btain and mainta in the

following records for five years:

Copies of CPCs for each product (if the product is manufactured at more than one

facility, you must have separate CPCs for products manufactured at each facility);

Test reports for each CPSC-accredited, th ird party test for each product (if the

product is manufactured at m ore than one facility, you must have separate test

reports for products manufactured at each facility);

The Periodic Testing Plan, includi ng records docum enting evaluation anddetermination of appropriate testing intervals and samples sizes;

Any Production Testing Plan used to exte nd the Periodic Tes ting Plan interval

beyond one year, including production test results;

Any test failures and corrective action taken;

Documentation of materials changes to the products; and

Undue influence policies and training.

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B. Certification of Non-Childrens Products

A General Conformity Certificate (GCC) for non-childrens products must be based on actual

testing of the finished product or the use of a reasonable testing program. Failure to comply withthis requirement can lead to re jection of product imports into the United States, product recalls,

and civil and crim inal penalties. A listing of standards that require a GCC based on actual

testing or a reasonable testing program is available at http://www.cpsc.gov/cgi-bin/labsearch/.

Additional information on certificates of conformity for non-childrens products can be found athttp://www.cpsc.gov/ABOUT/Cpsia/sec102FAQs3.pdf.

The CPSC has not yet established form al testing requirements for certification of non-childrensproducts. The CPSC ha s issued a proposed rule containing requirem ents that the C PSC may

mandate in the future, and CPSC staff has issued guidance on its best pract ices for a reasonable

testing program. This information from the CPSC may be helpful in developing your reasonabletesting program, but it is not m andatory at the cu rrent time. The proposed rule is a vailable at

http://www.cpsc.gov/businfo/frnotices/fr10/testing.pdf. The staff guidance is available athttp://www.cpsc.gov/businfo/generalusefaq.html#q14.

C. CPSC Rule on Product Certificatio n Based on Testing Conducted by

Another Party Third Party Finished Product or Component Part Testing

The CPSC has issued a rule that explains when and how Ross can use and/or rely on testing fromits vendors and suppliers for CPSIA certification (the Reliance Rule ). This includes finished

product testing from another party, and testing of component parts by a pa rty further upstream.

This rule sets forth requirements that all parties in the supply chai n must follow in order to relyon testing perform ed by a party supplying finished products or com ponent parts. The rule

became effective on December 8, 2011.

1. General Requirements Reliance on Testing Done by Another Party

The Reliance Rule establishes requirements that Ross, as the importer of record, must follow to

rely on testing perform ed by manufacturers and/or component part suppliers for purposes ofissuing a G CC or CPC. This applies to finished product test ing performed by you, and

component part testing performed by you or your suppliers, for a ll products that you supply to

Ross that are subject to CPSC standards, when Ross is the importer of record both childrensand non-childrens products.

You must provide the following information and documents for each product in order for Ross toissue a GCC/CPC. Most of this information should appear on your certification test reports.

Identification of the finished product or component tested;

Identification of the lot or batch number of the finished product or component to

which the testing applies;

Identification of the applicable CPSC rule(s) that apply to the finished product orcomponent that was tested;

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Identification of the testing method and sampling protocol that the lab used;

The date when the finished product or component was tested;

The test result for each standard;

Identification of the party th at conducted each test, a nd a statement by that partythat all testing was performed as required in the CPSIA.

Finished product certificates or component part certificates, if applicable; Records tracing component parts used to manufacture the product to the testing

performed by the testing party; and

A statement from each person th at issued a certificate or testing party that whilethe finished product or component part was in its custody, it exercised due care to

ensure compliance with the rule.

More information is available on these requirem ents athttp://www.cpsc.gov/businfo/frnotices/fr12/testrelyfinal.pdf and

http://www.cpsc.gov/info/toysafety/3ptfaq.html.

2.

General Requirements Component Part Testing

Unless the product is subject to a CPSC rule th at requires testing the finished product, the

Reliance Rule allows GCCs and CPCs to be base d on testing of the component parts that m ake

up the finished product, under the following conditions:

Component part testing m ust be sufficient to ensure that the finished product

complies with all applicable rules; and

The component part tested m ust be identical to the com ponent part used in the

finished product, and the component part in the finished product must be traceable

back to the component part test.

As with the Reliance Rule requirem ents, you must provide Ross with the following information

and documentation. W ithout this infor mation and docum entation, Ross cannot issueGCCs/CPCs for your products based on component part testing:

Identification of the component part tested;

Identification of the lot or batch num ber of the com ponent part to w hich thetesting applies;

Identification of the applicable CPSC rule(s) that apply to the component part that

was tested;


The date when the component part was tested;


Identification of the party th at conducted each test, a nd a statement by that party

that all testing was performed as required in the CPSIA;

Component part certifications, if applicable;

Records tracing component parts used to manufacture the product to the testing

performed by the testing party; and

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III. VENDOR RESPONSIBILITIES

Ross has developed a set of procedures to ensure that you provide Ross with the information and

documents necessary to evaluate and certify your products. Som e of these inform ation and

document requirements apply to your m anufacturing facilities; others relate to your products.You only need to provide the inform ation and documents relating to your m anufacturing

facilities once per year, when the inform ation is updated, or when requested by Ross. However,

you need to provide the information and documents relating to your products manufactured on orafter February 8, 2013 before Ross can accep t any orders for those products, and when

information is updated. You must supply reco rds and docum entation to Howard Cowart at

[email protected].

If you have any questions regarding these re quirements, please contact Rosss team : (1)

Elizaveta Golovatskaya, Product Sa fety Coordinator, (917) 229-6470,[email protected]; or (2) Tracey Meyer, Corporate Counsel & Director, Product

Compliance, (212) 944-3526, [email protected]

A. Vendor Requirements for Childrens Products

The following procedures apply to all childre ns products you supply to Ross. For products

manufactured on or before Fe bruary 8, 2013, you m ust provide Ross with a test report on

finished products performed by CPSC-accredited, third party tes ting labs and the infor mationrequired by the Reliance Rule. For childrens products manufactured after February 8, 2013, you

must comply with the following requirements.

1. Requirements for Each of Your Manufacturing Facilities Ross

Childrens Product CPSIA Compliance Questionnaire

The Ross Childrens Product CPSIA Com pliance Questionnaire, attached as Appendix A, is

designed to provide Ross with inform ation on your CPSIA compliance program, including yourundue influence policy and training , and your co rrective action plan. For each manufacturing

facility you use to m anufacture childrens products, you m ust complete the Questionnaire andprovide it to Ross on an annual basis, or when ch anges in your m anufacturing facilities require

an update. Ross will not approve any purchase orde rs for your childrens products without first

receiving and reviewing your completed Questionnaire.

2. Requirements for Each Childrens Product You Supply to Ross

For each childrens product you supply to Ross for which Ross is the im porter of record, youmust create and provide to Ross a Technical File containing:

Ross Product Cover Form

Certification test repo rts, including corrective action p lan documents andcomponent part testing, if applicable, and docum ents required by the Reliance

Rule;

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Please note that a m ajority of the Reliance Rule information can be provided

on your certification test reports please consult with your testing lab;

Periodic Testing Plan and test reports, if applicable;

Production Testing Plan and test reports, if applicable; and

Material change tracking documents and test reports, if applicable.

Ross will not issue a CPC for the product or permit it to ship without receiving and approving the

Technical File in advance. Ross may request additional information regarding any of the above

requirements in conjunction with its review. Please be aware that it is your obligation to provideRoss with additional documentation for the Technical File as you obtain it. For example, if you

make a material change to the product and pe rform new ce rtification testing, you must notify

Ross of this fact and provide the necessary documentation.

a. Ross Product Cover Form

The first step in providing your Technical File to Ross is to fill out the Ross Product Cover Form

(Cover Form). Please see Appendix C for a copy of the Cover Form. On the Cover Form, youwill provide Ross with the basic infor mation it needs to review an d assess your products

Technical File, including whether you test a child rens product subject to a Periodic Testing

Plan.

b. Certification Test Reports

You must provide test reports demonstrating compliance with all ap plicable CPSC-enforced

rules, standards, ban, and regulations, performed by a CPSC-accred ited, third party testing lab.This includes all finished product test reports and/or component part tests.

Test reports must contain all app licable information required by the Reliance Rule (s ee Section

II.C), including:

Identification of the finished product tested;

Identification of the lot or batch num ber of the finished product to which thetesting applies;

Identification of the applicable CPSC rules that apply to the finished product that

was tested;


The date when the finished product was tested;

Identification of the party th at conducted each test, a nd a statement by that party

that all testing was performed as required in the CPSIA; and

Records tracing com ponent parts used to manufacture the product to thecomponent parts tested by the testing party.

Please consult with your testing lab to ensure th at this information appears on your certificationtest reports.

Ross will review all test reports you provide to determine compliance with all applicable CPSC-

enforced rules, standards, bans, and regulations . Ross has provided tes ting specifications for a

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number of childrens product categories in Appendix H. Ross will compare your testing to these

specifications. If you do not test to these sp ecifications, Ross will reject your products until youhave performed additional certification testing sufficient to show compliance.

Please note that all test reports must reflect testing of the actual childrens product you aresupplying to Ross (that is, tests of sa mples taken from the batch/lot/production run you are

supplying), or testing performed subject to a Periodic Testing Plan. If the testing is of the actual

childrens product you are supplying to Ross, Ross m ust be able to determ ine this fromreviewing the test report (for example, the test report must list the batch/lot/production run on it).

If the testing is perform ed subject to a Periodic Testing Pl an, you m ust provide records

demonstrating this (for example, your Periodic Testing Plan and supporting documents.

i. Corrective Action Plan Documents

If the certification testing for products you supply to Ross resu lted in failures, you must provid e

Ross with docum ents demonstrating implementation of your corrective action plan andcorrection of the failure. This in cludes records demonstrating that you i nvestigated the failure,

took corrective action, and obtained new certification testing.

ii. Component Part Test Reports

Ross must be able to trace the com ponents in the products you supply to Ross back to the test

report for the com ponent. All com ponent part test reports m ust identify the batch/lot of

component tested, and you m ust include records showing that the com ponents in that batch/lotare the components used in the products you supply to Ross. If you rely on component part tests

and Ross cannot trace the com ponents to the test re ports you provide, Ross will reject your

products until you perform additional finished product testing.

c.

Periodic Testing Plan Only F or Childrens Products YouContinuously Produce

For childrens products you m anufacture on a con tinuous basis and test subject to a PeriodicTesting Plan (as discussed in Section II.A.1.c), you must provide:

A written copy of your Periodic Testing Plan for each product; and

All test reports associated with your Periodic Testing Plan for the product.

Your Periodic Testing Plan m ust include a de scription of how you de termined the testingfrequency and number of samples to test. Ross will review your Periodic Testing Plan to as sess

whether it is designed to ensure with a high degree of assurance that childrens products

manufactured after the initial CPSC-acc redited, third party testing comply with all applicable

consumer product safety rules. If you do not pr ovide a written copy of your Periodic TestingPlan and description of how your determ ined testing intervals and sam ple sizes, Ross will not

accept your childrens product.

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i. Production Testing Plan Only If Applicable

If you use production testing in connection with your Periodic Testing Plan, you must provide a

written copy of your Production Testing Plan and th e related test results to Ross for its review.

Your Production Testing Plan m ust include a description of how you de termined the testingfrequency and number of sa mples to test. Ross will review your Pr oduction Testing Plan in

conjunction with your Periodic Testing Plan to assess whether it is designed to ensure with a

high degree of assurance that childrens products manufactured after the initial CPSC-accredited,third party testing com ply with all applicable consum er product safety rules. If you do not

provide a written copy of your Pr oduction Testing Plan and desc ription of how you determ ined

appropriate testing intervals and sample sizes, Ross will not accept your childrens product.

d. Material Change Log and Related Test Reports

You must provide Ross with r ecords of any m aterial changes in the substances, com ponents,

processes, and/or design of your childrens products, as well as reports of testing performed by aCPSC-accredited third party testing lab after the ch ange. We have inclu ded a sample Material

Change Log for tracking material changes and the associated test reports at Appendix G.

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B. Vendor Requirements for Non-Childrens Products

The following procedures apply to products you supply to Ross that are not prim arily designed

or intended for children age 12 years and younger.

1.

Ross Non-Childrens Product CPSIA Compliance Questionnaire

The Ross Non-Childrens Product CPSIA Compliance Questionnaire, attached as Appendix B, isdesigned to provide Ross with infor mation on your CPSIA com pliance program for non-

childrens products, including whether you use a reasonable testing program. You m ust

complete and provide to Ross the Questionnair e on an annual basis, or when changes to

manufacture or production require an update. Ross will not approve any purchas e orders foryour non-childrens p roducts without first receiving and reviewing your com pleted

Questionnaire.

2. Requirements for Each Non-Childrens Product You Supply to Ross

For each non-childrens product you supply to Ro ss for which Ross is the im porter of record,

you must create and provide to Ross a Technical File containing:

Ross Product Cover Form;

Certification test reports, including any component part testing; and

Reasonable Testing Program description and supporting documents, if applicable.

Ross, as importer of record, m ust receive and review this Technical File prior to issuing a GCCfor the product and permitting it to ship. Ross may request additional information regarding any

of the above requirements in conjunction with its review.

a. Ross Product Cover Form

The first step in providing your Technical File to Ross is to fill out the Ross Product Cover Form

(Cover Form). Please see Appendix C for a copy of the Cover Form. On the Cover Form, you

will provide Ross with the basic infor mation it needs to review an d assess your productsTechnical File, including whether you test your non-childrens product subject to a Reasonable

Testing Program.

b. Certification Test Reports

You must provide Ross with all certification tests for your non- childrens products. This

includes all finished product te st reports and/or com ponent part tests performed on your non-childrens product.

Test reports must contain all app licable information required by the Reliance Rule (s ee Section

II.C), including:

Identification of the finished product or component tested;

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Identification of the lot or batch number of the finished product or component to

which the testing applies;

Identification of the applicable CPSC rule s that apply to the finished product or

component that was tested;

Identification of the testing method and sampling protocol used;

The date when the product or component was tested; Identification of the party th at conducted each test, a nd a statement by that party

that all testing was performed as required in the CPSIA; and

Records tracing com ponent parts used to manufacture the product to thecomponent part testing performed by the testing party.

Please consult with your testing lab to ensure th at this information appears on your certification

test reports.

Ross will review all test reports and other information you provide to determine compliance with

all applicable CPSC-enforced rules, standards, bans, and regulations. Ross has provided testing

specifications for a number of non-childrens product categories in Appendix H. Ross willcompare your testing to these specifications. If you do not dem onstrate compliance with these

specifications, Ross will reject your products or require that you pe rform additional certification

testing.

Please note that all test reports must reflect testing of th e actual non-childrens product you are

supplying to Ross (that is, tests of sa mples taken from the batch/lot/production run you aresupplying), or testing performed subject to a Reasonable Testing Program. If the testing is of the

actual non-childrens product you are supplying to Ro ss, Ross must be able to determ ine this

from reviewing the test report (for exam ple, the test report must list the batch/lot/production runon it). If the testing is perf ormed subject to a Reasonable Te sting Program, you must provide

records demonstrating this.

c. Reasonable Testing Program Documents, If Applicable

If you are using a Reasonable Testing Program , you must provide a description of the program

and all related documents, including any test reports for testing performed on the product.

C. Requirements for Use of Component Part Testing for All Products

If you rely on testing of com ponent parts, you must include the following information in your

Technical File. W ithout this information, Ross will not issue a CPC or GCC for your product,

which may result in shipping delays or cancellation of the order.

Identification of the component part(s) tested;

Identification of the lot or batch num ber of the com ponent parts to w hich the

testing applies;

Identification of the applicable CPSC rule(s) that apply to the component part;


The date when the component part or finished product was tested;


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Identification of the party that conducted each test and a statement by that p arty

that all testing was performed as required in the CPSIA;

Component part certificates;

Records tracing the component parts us ed to m anufacture the product to the

testing performed by the testing party; and

A statement that while the component part was in your custody, you exercised duecare to ensure compliance with the rule.

IV. ROSSS ROLE AS THE IMPORTER OF RECORD

A. Rosss Due Care Responsibility

As the importer of record that will issue th e CPC for your childrens products, or the GCC for

your non-childrens products, Ross must exercise due care in eval uating the Technical Files andother documentation you provide. As a result, Ro sss review of the T echnical Files for your

products will be qualitative and focused on determining whether your approach to testing, testing

plan(s), and supporting docum entation demonstrate and achieve a high degr ee of assurance thatyour products comply with all applicable standards.

To make these determinations, Ross will focus on two primary factors: (1) its evaluation of eachvendor and (2) the general risks associated with the vendors products.

1. Vendor Evaluation

Before accepting any purchase orders for products that Ross will import after February 8, 2013and that will require a GCC or CPC, Ross will evaluate each vendor to determ ine whether the

vendor has created and im plemented a sufficient production and quality control system . Ross

will consider a number of factors, including but not limited to:

Rosss relationship with the vendor, including the amount of time the vendor has

been supplying the company with products;

Rosss knowledge and understanding of the vendors awareness of CPSIA

requirements;

Rosss knowledge of the vendors production processes and approach to testing;and

The vendors com pliance history, includ ing past quality c ontrol issues and

product failures.

Ross expects the vendor evaluation process to b e a cooperative process. Vendors will have an

opportunity to provide Ross with ne w or additional information as their approach to testing andcertification develops and improves (if necessary) over time.

2. Product Assessment

To evaluate the general risks associated with a vendors products, Ross will consider a number offactors, including but not limited to:

15


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16

Common understandings of product risk within the industry;

The standards, rules, regulations, and bans associated with the vendors products; and

The extent and severity of potential injuries that could result from a vendors product ifdefective.

3.

Rosss Determination

Ross will initially collect inf ormation from the Ross Childrens Prod uct CPSIA Com pliance

Questionnaire and the Ross Non-Childrens Pr oduct CPSIA Compliance Questionnaire. Using

this information, Ross will m ake an initial qualification of the vendor to supply products thatrequire a CPC or GCC. Ross m ay make that qualification contingent on providing additional

information, independent factory audits, or take other measures it deems necessary to m eet its

obligations to assess you and your products.

If Ross determines that the inf ormation a vendor has provided is not su fficient to qualify the

vendor to supply products requiring certification, Ross will not order any such products until thevendor demonstrates an appropriate compliance plan.

B. Recordkeeping/Technical File

Each vendor has an obligation to create and m aintain a Technical File for each of its productsthat contains records regarding testing and cer tification. The vendor m ust also m aintain a

Technical File for its childrens product m anufacturing facilities regarding its undue influence

policy and training and its correc tive action plan. A vendor m ust maintain this Technical Filefor five years from the last date of manufacture.

Each vendor is also are required to provide th is Technical File to Ross for its review andassessment, and Ross, as the im porter of record, will m aintain its own Technica l File f or the

same five-year period.

For products manufactured on a continuous basis, a vendors recordkeeping obligation includes

providing necessary updates of the Technical File to Ross when it obtains additional informationnecessary to product certification. This includ es, but is not lim ited to m aterial changes, test

failures, and corrective m easures. W hen a vendor generates new testing and certification

documents, it must notify Ross and provide those documents to Ross.


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APPENDIX A: Annual Ross Childrens Product CPSIA Compliance Questionnaire

Vendor Name (Vendor): __________________________________________

Factory Name (Factory): __________________________________________

Factory Address: __________________________________________

__________________________________________

1. The CPSC Childrens Product Testing and Certification Rule requires that you establish an undue

influence policy, and train your personnel that interact with CPSC-accredited third party testing labs tosafeguard against undue influence.

Do you have an undue influence policy (yes/no)?

Please describe your undue influence policy?

Is your personnel trained on your policy (yes/no)?

Please describe how you train your personnel.

Do you keep records of this training?

Where do you keep these records?

How long do you keep these records?

2. The CPSC Childrens Product Testing and Certification Rule requires that you establish a corrective

action plan to assess and correct failing test results for your childrens products.

Do you have a corrective action plan for products that fail testing (yes/no)?

Please describe this plan in detail.

Please describe the action steps within your corrective action plan to find the root cause of

product failures.

What steps do you follow to correct product failures?

How do you document product failures and their correction?

A-1


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APPENDIX B: Annual Ross Non-Childrens Product CPSIA Compliance Questionnaire

Vendor Name (Vendor): __________________________________________

Do you utilize a Reasonable Testing Program to certify your non-childrens products? Yes No

Please describe how you comply with CPSIA requirements for non-childrens products.

Do you consult with a 3rd

party testing lab?

How often do you send samples to 3rd

party labs for testing?

Do you test finished products?

What quality control measures do you use internally to ensure your products meet CPSIA

requirements?

________________________________________________________________________________________

If you rely on a Reasonable Testing Program, please provide a detailed description of the Program

(Including product testing policies and any procedures followed should a product fail testing).

B-1


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APPENDIX C: Ross Product Cover Form

(Required for Each Product Style and CPC/GCC)

Vendor Name (Vendor) __________________________________________

Factory Name (Factory) __________________________________________

Product Name (Product) ______________________ Vendor Style No.: ________ PO#: _________

Lot/Batch # provided to Testing Lab: Lot/Batch # provided to Ross:

Please Select One: Childrens Product Non-childrens Product

Please Select One: Continuously Produced NOTContinuously Produced

Please Select One: Component Part Testing Used NOComponent Part Testing Used

For Childrens Product, please complete Section A. below. For Non-Childrens Product, please complete

Section B. below. For all Products, you must complete Section C.

Section A: Childrens Product

For continuously produced Childrens Products, please identify whether you provided testing of the actualfinished product and/or components from the batch/lot supplied to Ross, or testing performed in a Periodic

Testing Program:

Test of Actual Product/Components from Batch/Lot Supplied

Test Based on Periodic Testing Program (include Periodic Testing Program Form)

Section B: Non-Childrens Product

If your Non-Childrens Product is continuously produced, please identify whether you tested the actual finished

product and/or components from the batch/lot supplied to Ross, or are relying on a Reasonable Testing

Program:

Test of Actual Product/Components from Batch/Lot Supplied

Reasonable Testing Program (include Reasonable Testing Program Form)

Section C: Reliance Certification for All Products

Vendor certifies that while Product was in its custody, Vendor exercised due care to comply with CPSIA.

By: __________________________________ Date: _______________

Name: __________________________________

Title: __________________________________

C-1


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APPENDIX D: Ross Childrens Product Periodic Testing Program Form

(Required for Each Childrens Product Style Subject to Periodic Testing Program)



Description of Periodic Testing Program

For Product, please describe your Periodic Testing Program. Please include the following information. If you have questions

regarding these issues, please consult with your CPSC-accredited, third party testing lab:

Third Party Testing:o How often do you send samples to a third party testing lab for testing

o How did you decide how often to send samples to a third party testing lab for testing?

o How many samples do you send for testing?

o How did you decide how many samples you sent for testing?

In-House Testing:o Do you perform in-house testing (Yes/No)?

o

o If so:

How often do you test samples?

How did you decide how often you test samples in-house?

D-1


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E-1

APPENDIX E: Ross Non-Childrens Product Reasonable Testing Program Form

(Required for Each Non-Childrens Product Style Subject to Reasonable Testing Program)



Description of Reasonable Testing Program

For Product, please describe your Reasonable Testing Program. Please include the following information. If you have questions

regarding these issues, please consult with a CPSC-accredited, third party testing lab:

How often do you test the product?

How did you decide how often to test the product?

Do you send samples to a third party testing lab, or do you test in-house?

How do you decide how many samples to test?


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APPENDIX F: Ross Childrens Product Certificate

ROSS PROCUREMENT, INC.

Importer Childrens Product Certificate

(Updated December 2013)

Product Identification Information

Description of Product:

Ross Purchase Order Number: Other:

Date (Month/Year) of Manufacture of the product:

Actual factory location (City/County/Country):

Lot/Batch # provided to Testing Lab: Lot/Batch # provided to Ross: :

Importer Information

Name of Importer: Ross Procurement, Inc.

Full Address: 4440 Rosewood Drive, Pleasanton, CA USA 94588

Telephone Number: 925-965-4231

Recordkeeping InformationName of Custodian of Test

Report:

DeAnn Kiker, Vice President, Logistics

Ross Procurement, Inc./Ross Stores, Inc.

Full Address:

1000 Retail Dr.

Fort Mill, South Carolina, USA29715

Corporate office:

4440 Rosewood Drive

Pleasanton, CA 94588

Att: Tracey Meyer, Director/Corporate Counsel, Product Compliance (212-944-3526,

[email protected])or Elizaveta Golovatskaya, Product Safety Coordinator, (917-229-6470,

[email protected]).


Email Address: [email protected]

Testing Information:

Date of Compliance Test:

Compliance Test Location

(City/County/Country):

Name of 3rdParty Testing Lab:

--Full Address:

--Telephone number:

--Test Report Number

Applicable Rules, Bans, Regulations and StandardsRoss Procurement, Inc. certifies that the above product complies with applicable rules, bans, regulations, and standards under

applicable Acts enforced by the U. S. Consumer Product Safety Commission indicated below. The certification as the importer is

based on information provided by the supplier and a test of the individual product or a reasonable testing program of testing by a

laboratory(ies) obtained or conducted by the supplier.

THE RULES, BANS, REGULATIONS, AND STANDARDS APPLICABLE TO THIS PRODUCT ARE INDICATED ON THE

NEXT PAGE.

F-1
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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Applicable Rules, Bans, Regulations, and Standards (Updated December 2013)

All Childrens Products

Check if

AppliesRule, Ban, Standard or Regulation

Law/Act

Regulation Citation

AllChildrens Products designed or intended primarily forchildren under 12 years including apparel, footwear, jewelry,furniture, home, etc.Total Lead Content (Substrate) CPSIA PL 110-314, Sec. 101

Childrens Metal Jewelry CPSIA PL 110-314, Sec. 101Phthalates CPSIA PL 110-314, Sec. 108

Toy Standard CPSIA ASTM F963-11

Bicycle Helmets CPSA 16 CFR 1203

Infant Bath Seats CPSIA 16 CFR 1215

Infant Walkers CPSIA 16 CFR 1216

Toddler Beds CPSIA 16 CFR 1217

Lead in Paint/Surface Coating CPSIA 16 CFR 1303

Childrens ATVs CPSIA 16 CFR 1420

Sharp Points FHSA 16 CFR 1500.48

Sharp Metal or Glass Edges FHSA 16 CFR 1500.49

Small parts FHSA 16 CFR 1500.50-53,1501Clacker Balls FHSA 16 CFR 1500.86(a)(5)

Dive Sticks and Similar Articles FHSA 16 CFR 1500.86(a)(7)-(8)

Electrically Operated Toys/Articles Intended for Use by Children FHSA 16 CFR 1505

Cribs (Full Size) FHSA 16 CFR 1508

Cribs (Non full size) FHSA 16 CFR 1509

Rattles CPSIA 16 CFR 1510

Pacifiers CPSIA 16 CFR 1511

Standard for the Flammability of Clothing Textiles FFA 16 CFR 1610

Childrens Vinyl Plastic Film FFA 16 CFR 1611

Standard for the Flammability of Childrens Sleepwear FFA 16 CFR 1615, 1616

Childrens Carpets and Rugs FFA 16 CFR 1630-31

Standard for the Flammability of Mattresses/Pads/Sets FFA 16 CFR 1632, 1633

Home Products

Check if

AppliesRule, Ban, Standard or Regulation Law/

ActRegulation Citation

Furniture (Non-Childrens) CPSIA 16 CFR 1303

Other Applicable Standards

Check if



Bicycle Helmets CPSA 16 CFR 1203Lawnmowers CPSA 16 CFR 1205

Swimming pool slides CPSA 16 CFR 1207

Lighters CPSA 16 CFR 1210, 1212

Automated residential garage door openings CPSA 16 CFR 1211

Candles with metal core wicks CPSA 16 CFR 1500.12

Adult Apparel FFA 16 CFR 1610

Adult PVC Products FFA 16 CFR 1611

Adult Carpets and Rugs FFA 16 CFR 1630/1631

F-2


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ROSS PROCUREMENT, INC.

Importer General Conformity Certificate

(Updated December 2013)

Product Identification Information

Description of Product:

Ross Purchase Order Number: Other:

Date (Month/Year) of Manufacture of the product:

Actual factory location (City/County/Country):

Lot/Batch # provided to Testing Lab: Lot/Batch # provided to Ross:

Importer Information

Name of Importer: Ross Procurement, Inc.

Full Address: 4440 Rosewood Drive, Pleasanton, CA USA 94588


Recordkeeping Information

Name of Custodian of TestReport:

DeAnn Kiker, Vice President, LogisticsRoss Procurement, Inc./Ross Stores, Inc.

Full Address:

1000 Retail Dr.

Fort Mill, South Carolina, USA29715

Corporate office:

4440 Rosewood Drive

Pleasanton, CA 94588

Att: Tracey Meyer, Director/Corporate Counsel, Product Compliance (212-944-3526,

[email protected])or Elizaveta Golovatskaya, Product Safety Coordinator, (917-229-6470,

[email protected]).


Email Address: [email protected]

Testing Information:

Date of Compliance Test:

Compliance Test Location

(City/County/Country):

Name of 3rd

Party Testing Lab:

--Full Address:

--Telephone number:

--Test Report Number

Applicable Rules, Bans, Regulations and Standards

Ross Procurement, Inc. certifies that the above product complies with applicable rules, bans, regulations, and standards underapplicable Acts enforced by the U. S. Consumer Product Safety Commission indicated below. The certification as the importer is

based on information provided by the supplier and a test of the individual product or a reasonable testing program of testing by a

laboratory(ies) obtained or conducted by the supplier.

THE RULES, BANS, REGULATIONS, AND STANDARDS APPLICABLE TO THIS PRODUCT ARE INDICATED ON THE

NEXT PAGE.

G-1
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Applicable Rules, Bans, Regulations, and Standards (Updated December 2013)

Home Products

Check ifApplies

Rule, Ban, Standard or Regulation Law/Act

Regulation Citation

Furniture (Non-Childrens) CPSIA 16 CFR 1303

Other Applicable Standards

Check if




Lawnmowers CPSA 16 CFR 1205

Swimming pool slides CPSA 16 CFR 1207

Lighters CPSA 16 CFR 1210, 1212

Automated residential garage door openings CPSA 16 CFR 1211

Candles with metal core wicks CPSA 16 CFR 1500.12

Adult Apparel FFA 16 CFR 1610

Adult PVC Products FFA 16 CFR 1611

Adult Carpets and Rugs FFA 16 CFR 1630/1631

All Childrens Products

Check ifApplies

Rule, Ban, Standard or Regulation Law/Act

Regulation Citation

AllChildrens Products designed or intended primarily forchildren under 12 years including apparel, footwear, jewelry,

furniture, home, etc.Total Lead Content (Substrate) CPSIA PL 110-314, Sec. 101

Childrens Metal Jewelry CPSIA PL 110-314, Sec. 101

Phthalates CPSIA PL 110-314, Sec. 108

Toy Standard CPSIA ASTM F963-11


Infant Bath Seats CPSIA 16 CFR 1215

Infant Walkers CPSIA 16 CFR 1216Toddler Beds CPSIA 16 CFR 1217

Lead in Paint/Surface Coating CPSIA 16 CFR 1303

Childrens ATVs CPSIA 16 CFR 1420

Sharp Points FHSA 16 CFR 1500.48

Sharp Metal or Glass Edges FHSA 16 CFR 1500.49

Small parts FHSA 16 CFR 1500.50-53,1501

Clacker Balls FHSA 16 CFR 1500.86(a)(5)

Dive Sticks and Similar Articles FHSA 16 CFR 1500.86(a)(7)-(8)

Electrically Operated Toys/Articles Intended for Use by Children FHSA 16 CFR 1505

Cribs (Full Size) FHSA 16 CFR 1508

Cribs (Non full size) FHSA 16 CFR 1509Rattles CPSIA 16 CFR 1510

Pacifiers CPSIA 16 CFR 1511

Standard for the Flammability of Clothing Textiles FFA 16 CFR 1610

Childrens Vinyl Plastic Film FFA 16 CFR 1611

Standard for the Flammability of Childrens Sleepwear FFA 16 CFR 1615, 1616

Childrens Carpets and Rugs FFA 16 CFR 1630-31

Standard for the Flammability of Mattresses/Pads/Sets FFA 16 CFR 1632, 1633

G-2


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APPENDIX H: Ross Childrens Product Testing Sample Size Form(Required for Each Childrens Product Style Subject to Actual Finished Product Testing Not

Childrens Products Subject to a Periodic Testing Plan)



Description of Sample Size Determination

For Product, please describe how you determined the number of samples to test. Please include the following information. If you

have questions regarding these issues, please consult with your CPSC-accredited, third party testing lab:

How many samples were sent to the lab for this style?

How was the amount of samples chosen?

Were there any differences /changes between the product tested and the product sent to Ross that may have occurred due to

how the product was made (yes/no)? If yes, please describe the differences/changes.

H-1


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APPENDIX I: Sample Undue Influence Policy

Sample Undue Influence Policy

Policy

[Vendor] is committed to complying with the Undue Influence requirements of the ConsumerProduct Safety Improvement Act and the Final Rule on Testing and Certification of Childrens

Products, issued by the Consumer Product Safety Commission. The Undue Influencerequirements prohibit manufacturers from exercising undue influence on a third party conformity

assessment body (i.e., a CPSC-accredited, third party testing laboratory). [Vendor] will not

tolerate any efforts to unduly influence third party conformity assessment bodies.

Procedure

Undue Influence Defined

Undue influence is any action taken by [Vendor] personnel that could undermine the integrity oflaboratory test data used in the certification of childrens products.

Training

All employees that interact with testing labs will be trained to safeguard against exercising undue

influence on testing labs. If [Vendor] makes any substantive changes to this policy, all

employees that interact with testing labs will be retrained regarding those changes. Allemployees must sign a statement attesting to their attendance at the training.

Reporting

It is the responsibility of each employee to promptly report any incident of undue influence to[contact], who is responsible for investigating undue influence reports.

An employee is not required to report incidents of undue influence to [contact] if that person is

the individual who is exercising undue influence, or if the employee would feel more

comfortable reporting the incident(s) to his or her immediate supervisor or any other member ofmanagement.

An employee may also confidentially report incidents of undue influence directly to theConsumer Product Safety Commission. The Consumer Product Safety Commission can be

contacted at (800) 638-2772 or through http://www.cpsc.gov/cgibin/info.aspx.

Supervisors or managers who receive reports of, or otherwise observe, incidents of undueinfluence should immediately inform [contact] or another appropriate [Vendor] official, so that

an investigation may be initiated.

I-1
http://www.cpsc.gov/cgibin/info.aspxhttp://www.cpsc.gov/cgibin/info.aspx


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I-2

Investigation

Every reported incident of undue influence will be investigated thoroughly, promptly, and to the

extent possible, in a confidential manner.

[Vendor] will not tolerate retaliation against any employee for reporting an incident or

cooperating in an investigation of reported undue influence.

Corrective Action and Discipline

If undue influence is established, [Vendor] will take corrective action. [Vendor] will

immediately report such findings to the Consumer Product Safety Commission. Correctiveaction may also include, for example, retesting of the product implicated, training, and/or

disciplinary action ranging from verbal or written warnings up to and including termination of

employment, depending upon the circumstances.


32/39

J-1

APPENDIX J: Sample Material Change Log

Material Change Log

Please identify the product and details of the material chan ge made. This includes the date of the change, the t

material(s) or component(s), manufacturing process, or product design), a description of the change, the ID num

(finished product or component tests), and the signature of the person providing the description. On ce complreports for the change.

Childrens Product Identification

Product Name:

Vendor Style No: Purchase Order #:

DateType

(material/process/design)Description of Change Test Report

3/3/13 Material Changed supplier of plastic buttons ABC1234

5/7/13 Design Replaced buttons with snaps ABC9876


33/39

K-1

APPENDIX K: Product Specifications for CPSC Standards, Rules, Regulations, and Bans

Product Specifications for CPSC Standards, Rules, Regulations, and Bans

Below please find a lis t of CPSIA certifi cation standards, rules, regulations, and bans that apply to specifiedproduct categories. Please note that these lists include only those CPSC-enforced standards, rules, regulations,

and bans that require CPSIA certification. Other federal and/or state standards, rules, regulations, and bans may

apply to your products. It is you res ponsibility to individually assess each product to determine the appropriaterequirements.

CHILDRENS PRODUCTS

Infant and Toddler Bottles, Sippy Cups, Utensils, Bibs, Pacifiers, Teethers, and Other Infant and Toddler

Items To Help a Child Sleep, Feed, or Teethe

Standard Limits/Standard Test Methods

Lead in Paint and Surf aceCoatings:

90 ppm CPSC-CH-E1003-09

Lead in Substrate 100 ppm Metal: CPSC-CH-E1001-08 or

CPSC-CH-E1001-08.1

Non-Metal: CPSC-CH-E1002-08 or

CPSC-CH-E1002-08.1

Phthalates 1,000 ppm DEHP, DBP, or BBP i n toysor childcare articles

1,000 ppm DIDP, DINP, or DNOP in

toys or childcare article in tended for

children under 3 that can be placed in the

childs mouth

CPSC-CH-C1001-09.3 or GB/T22048-2008

Small Parts Shall meet small parts testing 16 CFR 1501 and ASTM F963-11

Sharp Edges and Points Shall meet sharp edges and points testing 16 CFR 1500.48, 16 CFR 1500.49,

and ASTM F963-11

Pacifier and Toy Pacifiers Shall meet safety requirements 16 CFR 1511 and ASTM F963-11

Teethers and Teething Toys Shall meet safety requirements ASTM F963-11

Toys Intended to be

Attached to a Crib orPlaypen

Shall meet safety requirements ASTM F963-11


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K-2

Childrens Jewelry


Lead in Paint and Surf ace

Coatings:


Lead in Substrate 100 ppm Metal: CPSC-CH-E1001-08 orCPSC-CH-E1001-08.1


CPSC-CH-E1002-08.1


Sharp Edges and Points Shall meet sharp edges and points testing 16 CFR 1500.48, 16 CFR 1500.49,and ASTM F963-11


35/39

K-3

Childrens Toys



Coatings:




CPSC-CH-E1002-08.1

Phthalates 1,000 ppm DEHP, DBP, or BBP i n toys

or childcare articles

1,000 ppm DIDP, DINP, or DNOP intoys or childcare article in tended for


childs mouth

CPSC-CH-C1001-09.3 or GB/T

22048-2008



and ASTM F963-11

Standard Consumer SafetySpecification for ToySafety

Various safety requirements (seehttp://www.cpsc.gov/cgi-bin/labsearch/for listing of all ASTM F963-11

requirements)

ASTM F963-11

Electrically Operated Toys Shall meet safety requirements 16 CFR 1505 and ASTM F963-11

Rattles Shall meet safety requirements 16 CFR 1510 and ASTM F963-11

Toys with Magnets Shall meet safety requirements ASTM F963-11

Clacker Balls Shall meet safety requirements 16 CFR 1500.86(a)(5)
http://www.cpsc.gov/cgi-bin/labsearch/http://www.cpsc.gov/cgi-bin/labsearch/


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K-4

Childrens Apparel (including Childrens Sleepwear/Loungewear)



Coatings:




CPSC-CH-E1002-08.1

Phthalates (sleepwear only) 1,000 ppm DEHP, DBP, or BBP i n toys


1,000 ppm DIDP, DINP, or DNOP intoys or childcare article in tended for


childs mouth


22048-2008

Flammability Shall meet flammability requirements 16 CFR Sections 1610, 1611, 1615,and/or 1616


37/39

K-5

Childrens Footwear



Coatings:




CPSC-CH-E1002-08.1


38/39

K-6

Infant Accessories (Bouncers, Prop Mats, Play Gyms, Walkers, Tummy Cruisers, Carriers, Diaper Bags,

Shopping Cart Liners, Step Stools)


Lead in Paint and Surf aceCoatings:


Lead in Substrate 100 ppm Metal: CPSC-CH-E1001-08 or

CPSC-CH-E1001-08.1


CPSC-CH-E1002-08.1

Phthalates (only toys and

childcare articles)

1,000 ppm DEHP, DBP, or BBP i n toys


1,000 ppm DIDP, DINP, or DNOP in

toys or childcare article in tended for


childs mouth


22048-2008



and ASTM F963-11

Infant Bath Seats Shall meet safety requirements 16 CFR 1215

Infant Walkers Shall meet safety requirements 16 CFR 1215

Play Yards Shall meet safety requirements 16 CFR 1221

Toys Intended to be

Attached to a Crib orPlaypen

Shall meet safety requirements ASTM F963-11


39/39

NON-CHILDRENS PRODUCTS

Furniture (Chairs, Tables, Stools, Benches, Ottomans, Storage Bins, Outdoor Furniture)



Coatings


Home Accents (Candles, Candle Holders and Accessories, Accent Textiles)


Metal Candle Wicks Lead content must not exceed 600 ppm 16 CFR 1500.17(a)(13)

Carpets and Rugs

Flammability of Carpetsand Rugs

Shall meet flammability requirements 16 CFR 1630; or 16 CFR 1631

Adult Apparel and Accessories


Flammability Shall meet flammability requirements 16 CFR 1610 (cloth ing textiles);

16 CFR 1611 (vinyl film)

Lingerie/Hosiery


Flammability Shall meet flammability requirements 16 CFR 1610 (cloth ing textiles);16 CFR 1611 (vinyl film)

Mattresses


Flammability Shall meet flammability requirements 16 CFR 1632;

16 CFR 1633