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Addendum: Product Safety Requirements for Children’s Apparel

The following information applies to international vendors incorporated outside the United States selling children’s products, whether serving as the Importer of Record (IOR) or using zulily as the IOR.There are a number of federal laws and regulations that, as an international entity, you will need to comply with in order to sell products within the United States. We ask that you become versed with these regulations to make your selling process run as smoothly as possible. Here at zulily, we audit all children’s products to make sure these laws and regulations are followed at all times. The information below lists zulily’s requirements in accordance with the Consumer Product Safety Commission (CPSC). Please read through these requirements thoroughly:

Required for audit:

  • Children’s Product Certificate for each vendor SKU / style
  • 3rd party test reports
  • Proof of Children Tracking Labels (upon request)
  • A minimum of 5 production samples per season

 

Guidelines Checklist:

  1. Children’s Product Certificate (CPC)
    • One CPC per vendor SKU / style
    • Must be completely and accurately filled out
    • All testing exemptions must include valid reason
    • Exemptions for flammability testing must include valid reason
    • CPC date of manufacture can’t conflict with test date
    • CPC validity based on 3rd party testing date
    • Importer of record name and contact information must be accurate
  2. 3rd Party Test Report
    • If applicable to a product, testing must include: (This is not a comprehensive list of all your regulatory obligations under the CPSC. However, it’s meant to provide you with an understanding of zulily’s requirements)

 

  • Must be issued by CPSC accredited lab
  • Valid only for one year from date issued
  • Testing must be completed for each style unless vendor has been approved for component part testing by zulily compliance department
    • Reports that list styles are valid for that style /SKU only
    • Reports that list components are valid for component listed only
  • Testing must include each color of screen print
  • The style/ SKU numbers on test reports must match the information provided to zulily upon SKU setup
    • Reports failing to list style/ SKU number previously provided will be denied unless:
    • The report contains an image of the tested product including all tested components
    • The style / SKU number listed on the CPC must match information given at SKU setup

3. Tracking Labels

  • Images of the tracking label on at least two different samples must be submitted.
  • ALL tracking labels must contain certain basic information, including:
    • Manufacturer or private labeler name;
    • Location and date of production of the product;
    • Detailed information on the manufacturing process, such as a batch or run number, or other identifying characteristics; and any other information to facilitate ascertaining the specific source of the product.
  • For more information, visit https://www.cpsc.gov/business–manufacturing/business-education/tracking-label/
  1. Component Certification
    • YKK and Scovill certificates may be accepted in lieu of testing if they are on company letterhead and specify components covered and are dated within the past year
    • Certifications from outside organizations, such as Global Organic Textile Standard (GOTS) and Oeko-Tex, will not be accepted in lieu of testing
  2. Vendor Samples
    • A minimum of 5 production samples per vendor per season will be required for review by zulily compliance
  3. Additional Documentation
    • Direct import vendors are required to provide or sign a statement of Reasonable Testing Program
    • Vendor is subject to workplace conditions assessment factory audit by independent third party.
    • A certificate of attestation is required if vendor seeks to certify test for more than one year
  4. Intertek
    • zulily’s preferred CPSC accredited 3rd party testing partner is Intertek

While 3rd party testing can be done with any CPSC-accepted lab (a list can be found here), we have a relationship with Intertek, which includes discounted testing packages for all tests we require. For any testing item not listed on the zulily test package, Intertek will offer a 30% discount on their prevalent toys, chemicals, hardlines, and textile testing price list. For more information, you can reach out to our Intertek account manager, Rajath Kumar (rajath.kumar@intertek.com).  For efficiency, work with the lab to bundle and complete component testing when applicable. We look forward to working with you and answering any questions you may have about our process. Please do not hesitate to reach out to us at compliance@zulily.com

 

More information can be found in the links below:

Consumer Product Safety Commission: https://www.cpsc.gov

Children’s Product Definitions and Guidance from CPSC: https://www.cpsc.gov/Business–Manufacturing/Business-Education/childrens-products

3rd party testing labs accepted by the CPSC: https://www.cpsc.gov/cgi-bin/labsearch/Default.aspx

Regulations, Laws, and Standards: https://www.cpsc.gov/Regulations-Laws–Standards

Children’s Product Certificate: https://www.cpsc.gov/Business–Manufacturing/Testing-Certification/Childrens-Product-Certificate-CPC

Small Batch Manufacturer Information: https://www.cpsc.gov/Business–Manufacturing/Small-Business-Resources/Small-Batch-Manufacturers-and-Third-Party-

Intertek: http://www.intertek.com

Tracking Label Requirement: https://www.cpsc.gov/Business–Manufacturing/Business-Education/tracking-label

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