Luckily, while I was in denial, a few things happened that make compliance a possibility. Items made from fabric don't need to be lead tested... but do need to be labelled. Items with buttons, zippers, snaps, etc. still need to be tested, but if they made from natural materials (i.e. wood), they don't need to be tested, just labelled.
So, I started looking into compliance again and I came up with a plan that I could hopefully do without having to increase my prices a ridiculous amount.
- stop using buttons on crowns - buttons will be replaced with wool beads
- replace buttons on capes and cuffs with natural wood buttons
- label products with contents, care instructions, manufactured location, website, lot number and date
- do all this for less than $1 per item
That last one is the problem. I'm having trouble keeping the cost of these changes down. Today I made some labels (see photo) by using transfer paper printed on the computer, cut to size and ironed onto ribbon. While a relatively easy and straight forward project, it took me a long time to make a total of 28 labels. Not cool. Not only that, the labels are not nice and soft - which I have issues with. And that time doesn't even account for the time that it'll take me to track all the information for each lot and the materials used.
So, I need to re-evaluate. It seems wrong to have to increase my prices several dollars just because of the labels I'm required to put on them. But I also don't have the time to invest in making labels. 28 labels is not going to last me very long. And because of the varying content of each item I make, it's also very expensive for me to have them printed for me.
And the buttons I need? Well, those are almost $1 per button. Compare that to the .10 a button I was paying before (most I found for even less). I am currently researching making these myself so that there is one large initial investment... but over time, it will keep my cost low.
So, CPSIA... I shake my fist at you!
** please note, I have not covered all the requirements of the CPSIA. I also recite these requirements as I understand them. If I have incorrect information, please feel free to post accurate information in comments.