29 January 2013
01.2009
CPSIA Testing & Certification:
The Learning Curve Phase
Proprietary and confidential. Do not copy or distribute.
● The Children’s Place is the largest pure-play children’s specialty apparel retailer
in North America
● The Children’s Place designs, contracts to manufacture and sells fashionable,
high-quality merchandise at value prices, primarily under the proprietary “The
Children’s Place” brand name
● The Children’s Place currently operates 1,100+ stores in the US and Canada, and
online at www.childrensplace.com
©The Children’s Place 2014 . All Rights Reserved.
Product Testing and Compliance Program
Safety
Quality
Performance/Durability
Established Product Testing Program
1. Testing Protocols and Standards
2. Test Results and Reporting Procedures
3. Corrective Action and Prevention Action (CAPA) Report and Remediation Procedures
4. Communication and Recordkeeping Procedures
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©The Children’s Place 2014 . All Rights Reserved.
CPSIA - 16 C.F.R. Part 1107 (“Part 1107 Rule”) Requirements
• create and implement a children’s products testing and certification program which provides a
“high degree of assurance” that the children’s products that have not been tested are just as
compliant with applicable children's product safety standards as products that have been
tested and passed all relevant tests
Testing and Certification Program Requirements:
1. certification testing performed by third-party CPSC-accredited laboratories
2. testing representative samples of children’s products
3. additional periodic testing
4. additional testing when there has been a material change in product design or
manufacturing process
5. establishment of safeguards against undue influence on third party laboratory
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Production Testing: Third-Party Laboratory Testing
• For children’s products, accredited third-party testing is required to support issuance of a
General Certificate of Conformity (GCC)/Children’s Product Certificate (CPC) certifying
compliance with applicable product safety rules and standards
• CPSC is required to maintain, on its internet website, an up-to-date list of entities accredited to
assess conformity with children’s product safety rules
http://www.cpsc.gov/cgi-bin/labsearch/
• NOTE: Each laboratory is accredited for specific rule(s) /standard(s)
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Production Testing and Compliance: Requirements
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Production Testing: Requirements
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Production Testing: Requirements
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Production Testing: (Example) Ready-to-Wear
DEVELOPMENT
• TRIM
1. Quality
2. Regulatory
• BASE FABRIC
1. Quality
2. Regulatory
PRE-PRODUCTION
• BULK FABRIC
1. Quality
2. Regulatory
• GARMENT
1. Quality
2. Regulatory
• CPSIA permits components parts testing
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IN-LINE
FINAL
PRODUCTION
• GARMENT
Quality
• GARMENT
Regulatory
Production Testing: (Example) Ready-to-Wear
ENHANCED IN-LINE TESTING
DEVELOPMENT
• Quality
• Regulatory
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IN-LINE
PRE-PRODUCTION
• Quality
• Quality
• Regulatory
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• Regulatory
FINAL
PRODUCTION
• Regulatory
Production Testing: (Example)
Ready-to-Wear In-Line and Final Production Testing Plan
Tests
Production
Quantity
(pieces)
# of Tests
(based on PRODUCTION
QUANTITIES)
Production
Duration
(weeks)
PRODUCTION QUANTITIES
Below 60,000
Children's Product
Certification
(3rd Party Accredited
Lab Testing)
# TESTS
PRODUCTION DURATION (weeks)
50%
Lead in Substrate
# of TESTS
(based on PRODUCTION
DURATION)
2
##
Less 5 weeks
##
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Phthalates
##
##
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Pull Test
##
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Drawstrings
##
##
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Tests
Production
Quantity
(pieces)
# of Tests
(based on PRODUCTION
QUANTITIES)
Production
Duration
(weeks)
PRODUCTION QUANTITIES
30%
70%
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##
Phthalates
##
Pull Test
Drawstrings
Lead in Substrate
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Below 120,000
# of TESTS
(based on PRODUCTION
DURATION)
Children's Product
Certification
(3rd Party Accredited
Lab Testing)
# TESTS
PRODUCTION DURATION (weeks)
2
5
##
##
##
##
##
##
##
##
##
##
##
##
##
##
##
##
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©The Children’s Place 2014 . All Rights Reserved.
Less 8 weeks
Additional Testing: Material Changes and Periodic Testing
Additional testing required:
• Material Changes in product design, manufacturing process or sourcing of component parts
• Periodic Testing
Testing Plan Requirements:
1. Indicate tests to be conducted
2. Number of samples to be tested
3. Intervals at which tests will be conducted
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Policy Against Undue Influence
Requirements
• Policy Statement
• Include Reporting Procedures
• Communication and Training
1. Internal - Code of Business Conduct
2. External - Policy Statement in Vendor Guide and Purchase Order terms and conditions
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Action Points:
1) Partner
2) Educate
3) Communicate
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M. Elena Hogan
The Children’s Place
(201) 558-2400
ehogan@childrensplace.com
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