Directly From the Source
After about 3 weeks of unanswered email and voicemail, I reached out to somebody from the CPSC yesterday in the Office of Compliance. Well, to be more precise, I was routed to them, but the point is I was finally able to get some solid answers.
The good news– If I believe my unfinished wooden toys do not require phthalate testing, then that is fine (as in, they contain zero plastic).
The not so good news– The toys DO require lead testing, and it is important here to note the difference between lead surface coating testing and lead content testing. I would need lead content testing, which I am going to start getting some quotes for.
The possibly good news– She also said the General Counsel told her there will be some information being issued in the very near future on unpainted wooden toys and lead requirements.
So there you have it, directly from the source.
The Blog for GW Pens 
Thanks for sharing that, John. Makes me hopeful that they will indeed start to consider the unintended consequences of this whole thing.
Great work! I know it’s a lot of effort to get answers from these people. I hope we see more info come from this.