Conformity tests for export to USA

Question posted by Jo Lochhead, on behalf of The Crafty Kit Company in EH41

Hello
I manufacture craft kits in the UK. A large US company is interested in the kits and asking me if I have the conformity tests in place to export to the US. I don't, and furthermore have no idea how to go about doing this and what is required. Can anyone help please?

Thank you
Jo

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David Bill, on behalf of ChemPlex Ltd in EH48.

The potential buyer is probably asking if the exports conform to US regulations, the easiest thing is to ask him exactly what regulations they refer to. In the USA some states have different regulations to other so you need to get details of the federal as a well as any state regulation

When you know what the regulations are you can then answer them

David

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Jo Lochhead, on behalf of The Crafty Kit Company in EH41.

Thank you that's helpful.
Jo

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Jo Lochhead, on behalf of The Crafty Kit Company in EH41.

Thank you that's helpful.
Jo

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Hi Jo
Since your kits look as though some may contain Wool, there may be regulations to do with whether it is from animal hair.
You may have to give your importer a breakdown of the materials used for them to check.
Somebody big like Michaels will expect you to do the work for them.
You can use a resource such as the European Commission Market Access Database
http://madb.europa.eu/madb/datasetPreviewFormIFpubli.htm?datacat_id=IF&from=publi
There are ways of doing it yourself ,rather than having to send it out to an expensive agency
Gilio

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Victoria Harman, on behalf of UK Trade & Investment USA in New York, NY.

Hi Jo,

As the others have said, I think this is likely an issue related to the components of your craft kits. We come across this sometimes when companies are importing products that contain wool, glue, etc. While I am not at liberty to speak on such regulations, I can think of a few resources that could be helpful to you:

1) Craft & Hobby Association - This is a US based trade association that hosts the craft industry's largest trade show in the USA, The CHA Mega Show (January in Anaheim, CA). They are likely to have some contacts that could advise on this issue. If you haven't worked with CHA already, I recommend you speak to the Director of CHA-UK who could introduce you to his American counterparts. His name is Craig De Souza [craig@cha-uk.co.uk].

2) Customs Agents - A Customs Agent can clear up a lot of regulatory questions that can affect the importation of consumer goods. They are at the port of entry where your goods will enter, which you can find on the CBP website. A complete directory of the various ports of entry can be found on the CBP Web site. (Locate a Port Of Entry - Air, Land, or Sea). http://www.cbp.gov/xp/cgov/toolbox/contacts/ports/ Click the state, then the port, then call the general phone number and ask to speak with the customs agent in the sector that your goods fall within. (If you are unsure of or haven’t decided the port where your shipment will arrive, or you are looking at importing through multiple ports, you may contact a service port of entry near where she/the goods are going.)

3) Consumer Product Safety Commission - This is the US Government Agency that regulates the safety of consumer goods products sold throughout the USA.
CONSUMER PRODUCTS SAFETY COMMISSION
www.cpsc.gov/en/Regulations-Laws--Standards/
301-504-7923 / 800-638-2772

I think these 3 resources should be able to answer all of your questions regarding regulations and conformity/safety standards.

Best,
Victoria

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Paul Bennett, on behalf of British Wonder LLC in United States.

Hi Jo,
Crafts can be very tricky because of all the possible content.
The best thing for you to probably do is to send a sample shipment of each item that customs can examine. You'll then have the correct classification and avoid any possible surprises when you do actually have your first shipment.
If you need any help, please let me know

Paul

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Victoria Harman, on behalf of UK Trade & Investment USA in New York, NY.

Hi Jo,

Just to add on to what Paul Bennett said - from what I understand, you can send in 1 sample of each individual product to US Customs for what is called a "Binding Ruling". They will then examine the items and determine a *binding* Harmonized Tariff Number. That classification will hold up no matter what port your product is shipped into. So, there will not be any surprises and the products should be regulated and taxed consistently. Here is the official page explaining this option:

"The binding ruling program enables importers and other interested parties to get binding pre-entry classification decisions prior to importing a product and filing entries with Customs and Border Protection (CBP). It is also to get binding guidance about other CBP regulations pertaining to marking of country of origin requirements.

Binding classification advice can only be given by the Office of Regulations and Rulings. The importer submits either an electronic request or a letter describing the product in detail and provides a sample to the CBP Information Exchange, National Commodity Specialist for a ruling. The importer generally receives a response within 30 days.

Tariff Classifications are binding, however duty rates are not. The program promotes compliance, uniformity and accuracy."

https://help.cbp.gov/app/answers/detail/a_id/279/~/binding-ruling-program

Best,
Victoria

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