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THE AMERICAN APPAREL AND FOOTWEAR ASSOCIATION'S (AAFA) COMMENTS, TESTIMONY AND LETTERS TO CPSC RE: THE CONSUMER PRODUCT SAFETY IMPROVEMENT ACT (CPSIA)

2/1/11: AAFA Welcomes CPSC Action to Extend Stay of Lead Testing and Certification Requirements

9/17/10: AAFA submitted comments to the CPSC opposing the application of third party testing requirements to children's apparel subject to Flammable Fabrics Act regulations.

-7/21/10: The AAFA has been collecting information ("evidence") from companies to see exactly how the testing rules have impacted their businesses. This information is important to help document to CPSC and Congress the economic impact of CPSIA.
-To continue gathering data, AAFA recently published two surveys online to gauge the impact of consumer product testing. One survey is for manufacturers, wholesalers and suppliers and the other is for retailers and licensors.
-If you are (or were) in the children's product business, we strongly urge you to fill out this survey online. It only takes a few minutes.
-The surveys are especially geared towards assessing the impact on businesses, and business awareness of, two proposed rulemakings that are due August 3, "Conditions and Requirements for Testing Component Parts of Consumer Products" and "Testing and Labeling Pertaining to Product Certification," as well as how the stay of testing and certification requirements impact companies' testing protocols and costs.
-To access the survey for manufacturers, wholesalers and suppliers please visit surveymonkey.com/s/D6S3D7N
-To access the survey for retailers and licensors please visit surveymonkey.com/s/D668GJT
 
-3/3/10: Prior to a Congressional hearing on the CPSC's FY2011 budget, AAFA submitted comments to the House Committee on Appropriations requesting that Congress fully fund the CPSC.
 
-2/26/10: AAFA submitted joint comments urging the CPSC to approve recommendations by AAFA and Intertek regarding a series of test methods for lead in coatings.
 
-1/11/10: AAFA joined with other trade associations in sending a letter urging the CPSC to seek authority from Congress to grant common sense, risk-based exclusions from the applicable total lead limits under the CPSIA.
 
-1/11/10: AAFA submitted comments to the CPSC regarding the pending testing rulemaking that will further define how manufacturers will have to test their products for compliance with product safety regulations.  
 
-12/15/09: AAFA joined with the U.S. business community in urging the CPSC to extend the current stay of enforcement with regards to third-party testing and certification under the CPSIA.
 
-10/29/10: Moving Beyond the CPSIA - Seminar Scheduled for Fashion Institute of Technology in New York
 
-10.28.09: AAFA joined with over two dozen other trade associations in sending a letter to Senator Mark Pryor (D-AR) urging him to hold a hearing soon on CPSIA. 
 
-10/1/09: AAFA submitted comments to the CPSC on its proposed factors for determining civil penalties for product safety violations.
-9/16/09: AAFA submitted comments on the CPSC Statement of Policy regarding component-based phthalate testing.
 
-8/25/09: AAFA presented testimony and submitted written comments to the CPSC public hearing on the CPSC's FY2011 agenda, strategy and budget.
 
-8/7/09: AAFA Welcomes Full Slate of CPSC Commissioners
 
-7/10/09: Letter to CPSC Chair Inez Tenenbaum from AAFA and Childrenswear Coalition urging the CPSC to find that fabric is inherently lead free
 
-7/9/09: Intertek and the AAFA Petition CPSC for Sensible Testing Practices
 
-6/17/09: AAFA submited comments to the CPSC arguing that the lead standard should apply to the components of a product and not to the sub-components.
 
-6/10/09: AAFA submited comments to the CPSC supporting the "Fashion Producers and Retailers'" petition requesting an exemption from the lead standard for all crystal and rhinestone materials.   
 
-5/14/09: Statement from AAFA
to the Subcommittee on Investigations and Oversight: "How the CPSIA Impacts Small Businesses"
 
-5/5/09: AAFA Welcomes Consumer Product Safety Announcements
 
-4/27/09: AAFA submits comments to the CPSC regarding Section 103 of the CPSIA, Tracking Labels for Children's Products.  AAFA requested the CPSC issue guidance that explicitly enhances recall effectiveness while permitting flexibility to accommodate the wide variety of products and production processes covered by the new tracking label requirement.
 
-4/20/09: AAFA submits comments to the CPSC regarding a proposed rulemaking on the content required for mandatory recall notices. 
 
-4/07/09: AAFA submits comments on the CPSC draft guidance regarding which children's products are subject to the requirements of the CPSIA phthalate standard
 
-4/01/09: AAFA President and CEO Kevin Burke, joined by other consumer product safety stakeholders and eight members of Congress, participated in a rally calling for amendments to the CPSIA.
 
-3/24/09: AAFA, as part of the CPSC Coalition, sent a letter to the CPSC requesting a stay of enforcement of certain tracking label provisions of the CPSIA.
 
-2/17/09: Joint submission by AAFA and 29 other trade associations in connection with lead exemptions, exclusion process and inaccessibility.
 
-2/17/09: AAFA Comments to CPSC in connection with lead exemptions, exclusion process and inaccessibility.
 
-2/03/08: Comments submitted by AAFA to CPSC in Support of Component Level Testing Under CPSIA
 
-1/30/09: AAFA led a group of 18 trade associations in submitting comments to the CPSC reiterating AAFA's position that lead does not occur in textiles and should therefore be exempt from the lead standard under the CPSIA.
 
-1/30/09: AAFA led a group of 15 trade associations in sending comments to the CPSC in response to a January 27 CPSC letter asking the industry to provide more details on its request to exempt fabric from the lead testing requirements under the CPSIA.
 
-1/27/09: Letter from CPSC asking follow up questions regarding the data provided at public meeting.
 
-1/22/09: CPSC Public Meeting on Apparel - Industry representatives discussed product testing programs and the results of testing for lead, and provided overviews of industry practices.
 
-1/12/09: AAFA submits second round of comments regarding the application of the Consumer Product Safety Improvement Act's phthalate ban to apparel and footwear.
 
-1/5/09: AAFA sent a letter to the leaders of the House and Senate Appropriations Committees urging Congress to fully fund the Consumer Product Safety Commission (CPSC).
 
-12/31/2008: AAFA organized a letter from the entire textile, footwear and apparel supply chain urging the CPSC to clarify several points related to the CPSC's proposed lead testing exemptions under the Consumer Product Safety Improvement Act (CPSIA) before issuing a final rule.
 
-12/30/08: AAFA submitted comments urging the CPSC to clarify several points related to the CPSC's proposed lead testing exemptions under the Consumer Product Safety Improvement Act (CPSIA) before issuing a final rule.
 
-12/22/08: An AAFA-supported multi-industry group sent a petition to the CPSC regarding the lead standard in the Consumer Product Safety Improvement Act (CPSIA).
 
-11/5/08: AAFA submits comments on the implementation of the Consumer Product Safety Improvement's Act (CPSIA) lead and lead in paint regulations.
 
-10.29.08: Comments Submitted to CPSC in Connection with Section 102 (relating to the conformity assessment certificate) of the Consumer Product Safety Improvement Act (CPSIA).
 
-10/10/08: AAFA sent letters to the CPSC urging the CPSC to immediately issue a formal opinion stating that children's footwear and apparel are not subject to the phthalate ban under the Consumer Product Safety Improvement Act.
 
 
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