MANHATTAN TOY SAFETY INFORMATION

January 9, 2009

RE: Consumer Product Safety Improvement Act

Dear Manhattan Toy Customer,

As you are aware, the Consumer Product Safety Improvement Act (CPSIA) is a law that imposes new requirements on a wide variety of children¡¦s products. Manhattan Toy is supportive of this law.

The purpose of this letter is to inform you of Manhattan Toy's process to ensure compliance with the requirements. We would also like to clear up some misconceptions regarding the new legislation and address some of its aspects; what this law means to Manhattan Toy and you. These aspects include:
  • Toy Safety Testing
  • Third party testing requirements
  • Reduced limits for lead in paint and coatings
  • Lead in substrates
  • Phthalates
  • General Conformity Certificates
  • Lot Tracking and Traceability
  • Labeling and Advertising


Toy Safety Testing

Safety has been important to Manhattan Toy from the beginning. We have used an independent third party testing laboratory to ensure all of our toys meet the ASTM and EN-71 safety standards. Effective September, 2009, the ASTM F963 standard will be required by law, ensuring that all toy manufacturers will have to test all toys entering the USA.

Manhattan Toy¡¦s standard testing protocol already addressed all but one of the new requirements. Upon the passing of the legislation in August, we changed our protocol to match the new requirements for lower limits of lead in paint and coatings. The one new requirement that we have not historically tested for is the presence of lead in the substrates (fabrics, plastics, wood). Beginning with product manufactured on or after November 1, 2008, we will have test reports to confirm compliance, however, we do not have the ability to test retroactively on items we no longer sell.

On January 8, 2009, the CPSC clarified requirements of new children¡¦s product safety laws taking effect in February, specifically addressing the issue of inventory at resellers. (Full press release is located at: http://www.cpsc.gov/cpscpub/prerel/prhtml09/09086.html) In this release, they stated the following:

The new law requires that domestic manufacturers and importers certify that children's products made after February 10 meet all the new safety standards and the lead ban.¨ As stated above, Manhattan Toy is complying with this rule. The release also states:

The new safety law does not require resellers to test children's products in inventory for compliance with the lead limit before they are sold.¨ Manhattan Toy¡¦s products meet all other aspects of this law in regard to testing, including the phthalate requirements, and we feel the inventory you currently have in stock is in compliance with the laws.

General Conformity Certificates GCC's are certificates which state that a product complies with all applicable safety rules, bans, or requirements of the U.S. Consumer Product Safety Commission. Manhattan Toy is able to provide these upon request via email or fax. They can only be provided once goods are packed for an order.

Lot Tracking and Traceability Effective August 14, 2009 manufacturers of children¡¦s products are required to place permanent, distinguishable marks on the product and its packaging to allow the location and date of production of the product to be ascertained. Manhattan Toy has included a tracking number on our products for several years. We have now made a minor adjustment to the method of marking to better allow us to confirm the date and year of manufacturing. We are also working to implement this tracking number on all packages where the product or label is not easily accessible at retail.

Labeling and Advertising The new CPSIA requires that if a product's packaging requires a precautionary statement (small parts, small balls, etc) then any direct means for consumer purchase must bear the same precautionary statement. This law does not apply to business- to-business catalogs. For this reason, the statements are not included in Manhattan Toy's catalog. Our Customer Service department is able to confirm which of our products carry a precautionary statement. Please contact them directly with a list of items you carry and they will be able to supply the information to you.

Manhattan Toy takes great care to ensure the safety of our toys. We certify that all of our products are in compliance with current federal safety standards, rules and regulations. In addition, all of our products will be properly tested, certified, and labeled as required by law.

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