If you make soap for children with embedded toys, the Consumer Product Safety Improvement Act (CPSIA) may apply to your products. If the toy is intended for use by the child after the soap is used, then the toy would fall under the CPSIA regulations. At this point, implementation of the regulations is still being worked out and there are daily updates at the CPSIA site. Be sure to watch them for updates.
Hopefully, either through the interpretation and implementation of the CPSIA by the Comsumer Product Safety Commission or through the passage of Sen DeMint’s bill, testing of toys done by the manufacturer will be sufficient, so your final product won’t have to ALSO be tested.
Keep an eye on the CPSC and their statements on the implementation of the bill. Meantime, contact your supplier and see what records and documentation they have on the safety of the toys your purchased and/or what they are doing to ensure the toys comply with the regulations. Remember, your supplier is probably also under the gun and likely working frantically to meet the requirements.
Also keep in mind there are special rules for toys intended for children under the age of three. If your soaps with embeds are intended for the very little ones, you’ll need to ensure they meet those requirements as well.
Marie Gale, President, HSMG