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Publetariat Dispatch: Will Children’s Book Self-Publishers Survive CPSIA?

Publetariat: For People Who Publish!

In today’s Publetariat Dispatch, The Book Designer, Joel Friedlander, examines the Consumer Product Safety Improvement Act’s chilling effects on self-publishers.

Do you know about the Consumer Product Safety Improvement Act of 2008? No? Do you think you ought to?

It’s absolutely critical that you know about this law if you—or your clients—produce books or other products for children.

I found out about the implications of this law only today. Jacqueline Simonds, who I interviewed here last year about indie book distribution, sent an email to a group of people concerned with indie publishing explaining her experiences learning about this law. She’s posting about it on her blog.

When I realized the impact this law can have on self-publishers, I knew I had to get you this information right away, and Jacqueline was kind enough to take time out of her day to do an interview with me.

Here’s some background on this law:

The Consumer Product Safety Improvement Act of 2008 is a United States law signed on August 14, 2008 by President George W. Bush . . . The law . . . increases the budget of the Consumer Product Safety Commission (CPSC), imposes new testing and documentation requirements, and sets new acceptable levels of several substances. It imposes new requirements on manufacturers of apparel, shoes, personal care products, accessories and jewelry, home furnishings, bedding, toys, electronics and video games, books, school supplies, educational materials and science kits. The Act also increases fines and specifies jail time for some violations . . . Because of the wide-sweeping nature of the law, many small resellers will be forced to discontinue the sale of children’s products.—Wikipedia


Just to reinforce the possible effects on indie children’s book publishing that this law could have, here’s a response to Jacqueline’s email from Dan Poynter, author of The Self-Publishing Manual and many other books on writing and publishing:

“The future of four-color children’s books is the iPad (and whatever comes next.) This is because of the cost of four-color printing, ship and truck transportation, carrying inventory, processing orders and Postal expenses. CPSIA will only accelerate the migration.”—Dan Poynter, ParaPub.com


You need to know about this. Here’s the interview with Jacqueline.

TheBookDesigner: What is CPSIA?

Jacqueline: The Consumer Products Safety Improvement Act (CPSIA) was developed to make sure testing was done on products intended for children under the age of 12. Specifically, it is aimed at toys and bedding that a child might put in their mouth. Books somehow got swept into it, possibly because of board books for toddlers.

How did you get involved with this subject?

I first heard about the CPSIA via the Self-Publishers Discussion Group. One of the members, who makes toys as well as books, picked up on it in the early stages. Since we are distributors, my first reaction was simply not to take on children’s books.

However, a new client approached me with one of the most extraordinary projects I’ve seen in a long time. I couldn’t turn it down. Well, yes I could.

The first thing I asked him is, “Is it CPSIA compliant?” Um, what? he replied. And that’s when he told me that the book files were in Southeast Asia about to print. I had him hold the print run until we could get certification lined up. It’s not inexpensive!

Can you tell us what a publisher has to do to comply with CPSIA?

A publisher must:

  • Place the name of the printer, their city and country and “batch number” (work order number) on the Copyright Page. 
  • You must have a lab report (or a statement from the printer in lieu of a lab report) stating that the book contains lead that is not in excess of 300 part per million. 
  • The printer or print broker must fill out a Certificate of Conformity (a sample is here: http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf). For Question #2, which asks under what sector of the CPSIA the printer/broker is certifying, the answer seems to be “Section 101” which covers lead content. 
  • You must submit the lab results and certification to your distributor (if you use one) or wholesaler when you enter a new children’s book into the book databases.

Wow, that sounds like a lot of complicated requirements. Are they for real?

It seems pretty ridiculous, doesn’t it? There’s a point at which well-intentioned laws go feral, and this is one of those moments. We all know that there have been several incidents of children’s toys imported from Asia that have been tainted. However, books are another matter.

When does all this take effect?

The law was supposed to go into effect August 2009 – and did for children’s toys. For books, the official date has been moved to December 2011.

So, no one is demanding this yet, right?

Unfortunately, the big wholesalers have taken this law very much to heart, and are demanding CPSIA certification NOW for new children’s book titles, even though the law doesn’t officially take effect until December. This makes some sense if you consider that a book being sold now will most likely still be in the system when the law goes into effect.

Is there any chance this will be overturned or delayed?

The Association of American Publishers has been riding herd on this since the beginning. They are hoping they can get Congress to modify the legislation so that it only covers books with toys or trinkets attached. The chances of this Congress doing anything in a timely fashion before the law takes effect in December is vanishingly small.

What do you think the response of the book manufacturers is going to be to this new requirement? Will they provide the materials and testing so individual publishers don’t have to do this all themselves?

I have discovered that American printers are taking on the responsibility of testing their inks, paper, glues and cardboard themselves, for all the materials they use in all books (that way they don’t have to do separate testing for individual books). For instance, Lightning Source International has testing on-file and has a standard letter of compliance. They also print their name, state and batch number on the back of the book.

However, foreign book printers don’t have any such program. I have a client who is being charged $600 to prove his book is in compliance.

I would recommend that people contact printers for their RFQ (request for quote) and require that the lab test be paid for by the printer. What will likely happen is that the price of your books will probably have a hidden testing fee attached.

Where can people find out more?

You can go to the main website http://www.cpsc.gov/about/cpsia/cpsia.html Pack a lunch. It takes a while to sift through all this.

Can I hire you as a CPSIA consultant?

Jacqueline Simonds Beagle Bay Books self-publishingYes. I’m available for consultation on this, as well as many other questions about publishing. You can e-mail me at jcsimonds@beaglebay.com or call me at 775.827.8654 (please take into account that I am on Pacific time). I’ll quote rates depending on how much work you need.

Jacqueline Simonds is a book shepherd/publishing consultant, publisher, author and book distributor. She is available for consultations and presentations on many aspects of publishing.



Jacqueline Church Simonds
Beagle Bay, Inc.
Books That Enlighten and Inform
Follow Jacqueline on Twitter: http://www.twitter.com/jcsimonds


This is a reprint from Joel Friedlander‘s The Book Designer.

Publetariat Dispatch: Fiction vs. Nonfiction Ebook Pricing in the Kindle Store

Publetariat: For People Who Publish!
This week, the folks at Publetariat bring us a post from Joel Friedlander, AKA The Book Designer, on the topic of ebook pricing. Why does fiction generally cost less than nonfiction, and is that okay?

Pricing of e-books is a constant source of discussion online, and we’ve seen the rebellions in the Kindle store when publishers were allowed to start setting their own prices last year.

Some books went up in price, as traditional publishers tried to bring e-book pricing more in line with print book pricing. On the other hand, readers keep looking at the lack of reproduction costs in e-books and often moved to lower-priced alternatives.

Three other factors that seem to be driving the instability of the e-book pricing situation:

  1. The tremendous increase in the volume of sales as the price declines toward $0.99, the lowest price (other than free) in the Kindle store; 
  2. The shift of royalty payements, which are 70% for books above $2.99, and 30% for books below that price; and 
  3. The ease of changing prices on your Kindle books, combined with the ease of tracking your sales on a daily basis.

To get an idea of where pricing is today, I went over to the Kindle store to have a look around.

Amazon says there are 659,063 nonfiction books in the Kindle store. I took a look at just the top 10 best sellers as of yesterday to see what the pricing looked like. Here’s what I found:

Top 10 Nonfiction Full-Length Kindle e-Books

  1. $6.13 Heaven is for Real by Todd Burpo, Sonja Burpo, Colton Burpo and Lynn Vincent,
  2. $12.99 Unbroken by Laura Hillenbrand,
  3. $11.99 The 17 Day Diet by Dr. Mike Moreno,
  4. $9.99 Be a Dividend Millionaire by Paul Rubillo,
  5. $9.99 Allies and Enemiesby Anne Maczulak,
  6. $12.99 The Dukan Diet by Pierre Dukan,
  7. $9.99 The Immortal Life of Henrietta Lacks by Rebecca Skloot,
  8. $9.99 Winners Never Cheat by Jon M. Huntsman and Glenn Beck,
  9. $9.99 Leading at a Higher Level by Ken Blanchard,
  10. $9.99 The Gospel of Ruth by Carolyn Custis James,

The average price of these e-books is $10.40. None of these e-books is self-published, by the way.

Then I went to look at the fiction titles, since this is the land of the $.99 bestseller. Here’s the way the top 10 look, pricewise:

Top 10 Fiction Full-Length Kindle e-Books

Amazon reports they have 267,838 fiction e-books in the Kindle store:

  1. $4.17 Water for Elephants by Sara Gruen
  2. $7.99 The Lincoln Lawyer: A Novel by Michael Connelly
  3. $9.99 Walking on Broken Glass by Christa Allan
  4. $3.82 A World I Never Made by James Lepore
  5. $9.59 Divine by Karen Kingsbury
  6. $0.99 The Innocent by Vincent Zandri
  7. $0.99 Vegas Moon (A Donovan Creed Novel) by John Locke
  8. $7.99 Shattered: A Daughter’s Regret by Melody Carlson
  9. $4.58 Deadworld by J.N. Duncan
  10. $12.99 The Fifth Witness by Michael Connelly

The average price of these books is $6.31.

This means that the average fiction e-book that’s in the top 10 in the Kindle store is retailing for a full 40% less than the average top-10 nonfiction e-book. That’s a huge hunk of change.

Does this mean it’s better to be a nonfiction author, if making money is your aim?

Yes, it does. Self-publishing has traditionally worked best for nonfiction authors with solid information-based books. There is no disputing that a new world of bookselling is upon us, and all the old rules will be scrapped or at least reexamined in the light of new realities.

Are we seeing a rebirth in fiction reading, arising from the easy availability of inexpensive novels? From anecdotal evidence, it seems so, and that is certainly a good thing.

What Price is Right For You?

I think there’s no formula that will help you set your prices. If you’re a novelist, by all means keep track of the experiments of authors like JA Konrath and Zoe Winters and Joanna Penn, you’ll learn a lot.

But this seems to be an area where you have to be willing to experiment to find the right spot for your books. Many novelists have reported selling more and more copies as they gradually lowered their price, to the point that giving up the 70% royalty, when you go below $2.99, just didn’t matter as much as the volume of sales rose. As Konrath says about his title The List, when he lowered the price from $2.99 to $0.99, he sold 20 times as many books.

Here’s what Joanna Penn had to say in her recent article on the e-book pricing situation. Joanna publishes both nonfiction and fiction, so it’s interesting to get her perspective:

I pay far more money for non-fiction books that will help me in a tangible manner than I will for fiction which I read once and then (often) forget. It’s not that I don’t value fiction writing, but the price you pay for entertainment has to be representative vs the price you pay for actionable content.

The answer? Since we are all, in a sense, direct marketers now, we should take a lesson from the direct marketing world: test everything, track the results, adjust your pricing if necessary, and test again. You will become an expert on your own book’s pricing, and this experience will be invaluable as you continue to bring more books to market.

I took this all into account when setting the price of A Self-Publisher’s Companion in the Kindle store at $8.99. Is it the right price? I’m not sure, since the book has been out just a few weeks. Will I experiment with the price? You bet I will, just like all you other direct marketers.

What have your experiences with e-book pricing taught you?

This is a reprint from Joel Friedlander‘s The Book Designer.