The CPSC announced yesterday (January 30) that they are issuing a stay on CPSIA testing and certification requirements until February 10, 2010. However, the 600 ppm limit on lead and 1000 ppm limit on phthalates still applies-- you just are not required at this point to prove that you tested for them. The stay does not apply to third party testing requirements for lead in paints and coatings, lead in metal children's jewelry, pacifiers and cribs.
TheSmartMama provides a good list of things to watch for lead content based on her XRF testing: "the components that may fail are rhinestones, crystals, zipper pulls, zipper bases, zipper stops, grommets, snaps, metal closures, pearl or opalescent plastic buttons, vinyl (stabilized with lead) and eyelets. Some screen prints may also fail."
I interpret this to mean that good judgement is your guide-- if you are unsure if a component used in your children's product contains lead, ask the manufacturer or reseller. If they can provide any paperwork certifying this, even better. It might even be worth establishing a testing program (a periodic XRF test of a portion of your zippers, for example) to ensure that the component complies with the mandated lead levels.
I'm relieved, as this keeps thousands of people from having to decide whether they want to break the law or keep their business afloat, which is not a fair choice. And I think this stay gives the CPSC time to write a well-thought-out certification policy and in the meantime, we will all learn a lot about potential sources of lead and how to avoid them.