In the second part of the series, I will explain my estimate in a little further detail which I realize I haven't revealed yet. In part 1 I tried to give a little background so it may or may not be helpful to review. The reason is that the CPSC is in a current state of chaos because they don't know either. The broad wording of the act makes it difficult to determine what is actually needed.
Reading between the lines of the Act, it is clear the CPSC assumes that we should already be doing extensive testing on our products. I am assuming they want everyone up to the same level of testing as the Big Box retailers. At a minimum, any style will need to conform to the Fabrics Flammability Act, Pthalate ban, and lead requirements. Since there is the little wrinkle in children's products about certified lab testing, I had to throw in the tests that I have done on my own.
The average testing for one of my styles:
Lead for every surface (each fabric, button, trim, etc)
Dimensional stability (shrinkage/growth), wash 3 times
Burst/strength (pull test on buttons, trims)
Grand total: $982
Now there is the possibility the flammability test would not be required because the fabric is of a certain weight. I included the cost of samples, shipping, and official lab report (yeah, they charge for this too). The real concern is the CPSC will expand requirements to include heavy metal testing, cadmium, formaldahyde, etc. It's clear they intend on applying more stringent ASTM standards over time. The cost could conceivably go higher.
What to do?
Kathleen at the Fashion-Incubator posted a list of concerns. And they are real concerns. This has the potential of bankrupting nearly every small design firm in the country. Send your questions directly to the CPSC. The CPSC is also accepting comments on the various requirements. Be sure to send yours. Various trade groups have begun formal complaints and petitions so stay tuned for developments.