CPSIA

As the guy who put the stuff on the Delano web site, I suppose I should weigh in.

The product must have less than 100ppm lead content and no pthalates.

The product must be labeled with the manufacturer and country info, as well as date or lot code for tracking. "Manufacturer" is construed to mean the final assembler of the product by most people. Also, stickers are not allowed.

Testing can be done anywhere.

That said, the US government just decreed that it will suspend the testing requirements for one year (until Feb 10, 2009), but that ALL products (not just new ones) must still meet the lead and pthalate requirements.

THEORETICALLY, the manufacturer can provide certification if they establish a "reasonable" testing program. Of course, the law doesn't say what is reasonable. On the other hand, the law is very vague as well on whether or not every SKU needs to be tested or if batch testing is acceptable.

Long story short: Make sure your printer/manufacturer has their ducks in a row or you might end up with unsaleable product a year from now. You may or may not have to foot the bill for $1000 worth of product testing.

No "exposable part" may have more than 100 parts per million of lead or any pthalates. That applies to everything but the shrinkwrap (which is thrown away immediately after purchase, so not counted).

Most printed games will be in compliance with these limits. It is the labeling and testing that will bite you in the behind down the road. You might have a perfectly safe game, but you have to be able to provide some kind of cert (from the mfr or from a lab) that states that is safe. Sadly, existing MSDS sheets aren't enough in most cases.

This seems like it will kill the small publisher unless:

1) They label it for ages 13 and up.
-or-
2) Make sure they use a printer who already has done all of this testing and is certified.

I see the need for this (especially for products coming out of China) but it is unfortunate for the small publisher. I imagine the Lot stamping will be most costly since they won't allow stickers. (Or is this something a printer can do rather easily?)

-Darke

Don't just label it that way if the game will be used frequently by kids under 12. I just spoke with one of the folks at GAMA about this (at their Toy Fair booth) and she says that there are provisions that prohibit this. I haven't read the full 150 pages of the law, but if that's true, it's cheaper to comply than circumvent if you face a nasty fine.

We should all move over to designing Roleplaying Games. Books have a general exemption. :)

Ummm....YOU are the importer in that case. You will have to provide certification if asked. Hopefully, your Spanish manufacturer can provide Material Safety Data Sheets or something so you don't have to pay for testing.

That said, if you are selling in ones and twos to individuals, I don't know that this will apply to you all that much. It's just not a big deal. If you want to ship to retailers or distributors in the US, then it might become an issue, because they might ask for docs. Joe Consumer probably will not.

Bingo. Yes - this is what is causing all the grief. Any idiot can print a card/board game that complies - most inks have a lead ppm of way less than 100 and paper is around zero - but certifying that you comply is the huge headache part.

i missed it, what's your new gig, gameprinter? did delano go down fully?