I want to fix the CPSIA, the CPSC's new lead testing law, and save all the various children's product industries from regulation-induced bankruptcy and collapse on February 10th as much as the next guy.
But I would like to do it in some way other than whipping the population into hysteria with out-of-control doomsday scenarios and hyperbole. Does it really help things to tell booksellers that they'll have to close down or destroy their entire children's book inventory on February 10th unless they can certify that every title is lead-free?
So what does CPSIA do? It mandates lead testing for ALL items intended for children under 13 or PERCEIVED as being for those under age 13. So items commonly regarded as "kids stuff" even if it is intended for adults, such as many comics, collectible books, high end popups, etc, still falls under the statute even though they're aimed at adult collectors.First and last, the rules are still being set, but if it's not a children's product--and graphic novels, "high-end popups," and four-figure rare books seem easily argued out of that category--it's exempt from the CPSIA ruling.
The manufacturer needs to provide a testing certificate to the retailer, which must be available for inspection, should a Consumer Product Safety Administration inspector come in. No certificate, the retailer can't sell it.
The truly bizarre part is that the new regulations apply retroactively. Even if it was printed 50 years ago and the publisher no longer exists, you need to have a certificate proving it's not filled with lead. Even if it is the only remaining copy of a rare children's book worth thousands of dollars and only will ever be handled by collectors, you cannot sell it because you can't prove it is not filled with lead.
Second, third, and fourth, the CPSC has "about a dozen staffers" working on the CPSIA, reviewing "hundreds of requests" for testing exemptions. So not only is there much that's unsettled about the rules, the agency barely has anyone to figure it out.
So do you think there's an army of CPSC lead inspectors waiting to swoop in on Feb. 11th and throw used book dealers and consignment store owners and wood toy carvers into prison for not having a lead certificate that meets some as-yet-undetermined CPSC rule? If you have products that you know have no lead in them, or you know have no possibility of having lead in them, you should care and organize and campaign for fixes to the CPSIA, but you should probably not panic--and you should definitely not burn your inventory of pre-Feb. 10 books.