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The limits on lead content in children's products have contributed to a successful endeavor by all federal health and safe agencies to lower the blood pb level in children. This page provides information for businesses seeking guidance on how to comply with the federal consumer product safety rules on lead.
Table of Contents
Overview
Test Methods and Procedures
International and Country Level Requirements
Exceptions and Exemptions
- Certain Products that Cannot Contain Lead
- Inaccessible Component Parts
- Sure Electronic Devices
- Off-Highway Vehicles
- Bicycles and Related Products
- Ordinary Books and Paper-Based Printed Materials
- Certain Used Children'southward Products
Product-Specific FAQs
- Production Packaging
- Arts, Craft, and Science Kits
- Jewelry
- Outdoor Playground Equipment
- Newspaper and Cloth Printing Inks
Overview
What are the federal requirements limiting the total pb content in children's products?
There are two distinct requirements concerning atomic number 82 in children'south products. One requirement concerns the total lead content of the children's production (discussed on this page), while the other requirement deals specifically with the levels of atomic number 82 contained in the paint or surface coating of a children'south production. Please run across our webpage onatomic number 82 in paint and similar surface coatings for information on this requirement.
Total Lead Content
With a few limited exceptions explained beneath, all children'due south products manufactured in or imported into the United States must not contain more 100 parts per 1000000 (ppm) of total atomic number 82 content in accessible parts.
Lead in Paint and Similar Surface Coatings
All children'south products, and some furniture, for adults and children, must not contain a concentration of lead greater than 0.009 percent (90 parts per million) in pigment or any like surface coatings. Household paints must also meet this requirement.
Where tin can I detect the police that limits total pb content in children's products?
Yous can discover the constabulary in section 101 of the Consumer Product Safety Improvement Deed of 2008 (CPSIA) (pdf) (Public Law 110-314), as modified by H.R. 2715 (Public Law No. 112-28, August 12, 2011) and in department ii(q)(1) of the Federal Hazardous Substances Human activity (pdf), 15 U.S.C. § 1261(q)(one) (FHSA).
What parts of the children's production must comply with the full lead content limits requirement?
All accessible component parts of the children'southward product must comply with the total lead limits requirement.
The total atomic number 82 content limits do not apply to component parts of a children'southward product that are not accessible to a child through normal and reasonably foreseeable use and abuse of the product. In addition to passing all applicative use and abuse testing, children'south products or component parts of children's products which are enclosed, encased, or covered by fabric must mensurate 5 centimeters or greater in all dimensions to exist considered inaccessible. Please come across 16 CFR 1500.87 and our section beneath on Inaccessible Component Parts for more than data.
What exercise I take to do to ensure that my product complies with the total lead content limits?
Manufacturers and importers of children's products must third party test their production using a CPSC-accepted laboratory.
At that place are, still, a limited number of exemptions and exceptions to the tertiary party testing requirement discussed further below.
Tin I rely on assurances from my component supplier that the testing they have performed on a product satisfies regulatory requirements and thereby avoid testing the same component part twice?
Yes, provided that sure atmospheric condition are satisfied. The Commission has issued a rule regarding testing component parts. You tin rely upon the examination results or a certification from a component office supplier if the requirements in our regulation at sixteen CFR function 1109 are met. That rule requires that in order to rely upon test results or a certification from a supplier, you must use "due care" to ensure that the tests results or the certificate is valid, and be given access to the underlying documentation, such as test results and attestations regarding how the testing was conducted and past whom. Mostly, certifications of a component part must satisfy the requirement for a children's product document, and must be based on the results of testing at a CPSC-accepted laboratory.
Once I test my product at a CPSC-accepted laboratory, what else do I need to do?
Manufacturers and importers must certify, based on the results of the third political party testing, that your children's product complies with the requirement limiting the total lead content.
Your certification must comprise all of the required elements of a Children's Product Certificate (CPC).
The right citation to include in the CPC for this total pb content requirement is: xv U.S.C. 1278a.
Test Methods and Procedures
What are the test methods for the ban on total lead content accepted by the Committee?
The applicative exam methods for the ban on total lead content are:
- Atomic number 82 Content in Children's Metal Products: Standard Operating Procedure for Determining Total Lead (Pb) in Metal Children's Products (including Children'south Metal Jewelry), Revision November 15, 2012, Exam Method CPSC-CH-E1001-08.3 (pdf).
- Pb Content in Children's Non-Metal Products: Standard Operating Procedure for Determining Total Atomic number 82 (Pb) in Non-Metal Children's Products, Revision November 15, 2012, Test Method CPSC-CH-E1002-08.3 (pdf).
Note : Following development of the initial versions of the examination methods for measuring lead in metal and nonmetal products, Examination Method CPSC-CH-E1001-08.1 (pdf) and Test Method CPSC-CH-E1002-08.1 (pdf), respectively, CPSC staff developed Test Method CPSC-CH-E1001-08.ii (pdf) and Test Method CPSC-CH-E1002-08.2 (pdf) with expanded options for the use of X-ray Fluorescence (XRF). CPSC staff further expanded the options for the apply of XRF in the electric current test methods: Test Method CPSC-CH-E1001-08.3 (pdf) and Test Method CPSC-CH-E1002-08.3 (pdf).
Accreditation to any of the previous versions of these examination methods will remain acceptable unless the Commission provides a notice of phasing out previous versions.
Is X-ray fluorescence engineering (XRF) approved for use past CPSC-accustomed laboratories?
Some XRF technology is approved to test sure types of homogenous materials, with limitations, such as certain metal materials, polymers and plastics, and crystal, ceramic, and other siliceous materials, in CPSC-accepted laboratories. Approval of XRF engineering science has reduced the cost of third party testing for pb content. (Additionally, there is a specific XRF applied science that is approved for apply in testing to the separate pb-in-paint requirements).
The applicable test methods for the ban on total pb content are listed to a higher place.
International and State Level Lead Content Requirements
If I have tested my product for its soluble atomic number 82 content for compliance with Europe'southward requirements, do I too demand to exam for full lead content with the CPSC's requirements?
Yes. All testing for lead content and other requirements must be performed by a CPSC-accustomed laboratory using the methods canonical by the Commission. Other countries have requirements and testing methods that differ from those of the CPSC.
Practice private states have other regulatory requirements apropos the amount of permissible full pb content?
Yes. Certain states, similar Illinois and California, accept other regulatory requirements apropos lead content. Yous may contact the attorney full general or Department of Health in each state for further guidance on specific state laws and requirements.
Exceptions and Exemptions
Certain Products that Cannot Contain Lead
Has the Commission fabricated a determination that certain products, by their nature, practise not contain atomic number 82 in excess of the legal limits?
Yes, the Committee has determined that certain classes of products practice not exceed the atomic number 82 content limits under section 101 of the CPSIA. The regulation includes determinations that sure 100 percent untreated, unadulterated products practise not need to be tested past a third party laboratory.
Some determinations relied upon are those exempting products such as pure forest (not plywood or other composites); paper and other similar products fabricated from cellulosic cobweb; CMYK ink printing processes, certain precious and semi-precious gemstones and other minerals (provided that the mineral or material is not based on lead or lead compounds); natural or cultured pearls; certain natural and manufactured fibers, such as cotton wool, wool, and polyester, amongst others; certain plant-derived and beast-derived materials, such every bit animal glue, bee's wax, seeds, nut shells, flowers, sea shells, leather; and finally certain stainless steel and precious metals, as listed. The list to a higher place is a sampling of the determinations that the Commission has made. Yous can detect the complete regulation, including the listing of determinations, at sixteen C.F.R. §1500.91.
Additionally, the Commission has determined that certain untreated and unfinished engineered woods products (EWPs), specifically, particleboard, hardwood plywood (without polyvinyl acetate), and medium-density fiberboard also exercise not exceed the total pb content limit and would not be required to have tertiary party testing for compliance with the total lead content limit. You can read more about this conclusion at 83 FR 28983 and at sixteen CFR Office 1252.
Does a third political party laboratory have to test my product to ensure that information technology satisfies the lead conclusion?
No. You may rely on the assertions of your supplier or upon test results from a not-third party laboratory or certification body. Yet, yous must keep records supporting your good faith exclamation. In the event that you knowingly rely on a false assertion, so you may be subject to substantial ceremonious and/or criminal penalties.
If all of the component parts of my product are inaccessible or else satisfy the lead determinations, am I still required to effect a children's product certificate ?
Yes. If you are issuing a Children's Product Certificate certifying to another children'southward product safety rule (such as the lead in paint limit), you volition demand to ensure that all applicable children'south production safety rules are certified to in Section two of the CPC.
I understand the determination that certain fabrics exercise non contain lead tin can exist afflicted by press or dyeing those fabrics. What do I need to do to ensure that my dyed fabrics fall nether these determinations and do non crave third political party testing?
As discussed in a higher place, certain natural fiber and manufactured fiber textiles have been determined to not contain levels of lead in excess of the limits and do not demand to be 3rd party tested. Those fabrics are:
- Natural fibers (dyed or undyed) including, but not limited to: cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, guanaco; and
- Manufactured fibers (dyed or undyed) including, merely not limited to: rayon, azlon, lyocell, acetate, triacetate, safety, polyester, olefin, nylon, acrylic, modacrylic, aramid, and spandex.
To use this determination, you must ensure that the textiles are not treated or adulterated in any way with materials that could innovate lead into the material. (Dyes are non considered to be a material that may introduce lead into a cloth.)
This means that if you choose to print on your fabric with after-treatment applications, including screen prints, transfers, decals, or other prints, you tin no longer rely on the determination. Yous must have your inks or your final products tested by a CPSC-accepted laboratory or have the ink manufacturer provide you with a Children's Product Certificate certifying that the inks passed testing by a CPSC-accepted laboratory.
Certain types of printing on textiles use inks that effectively deed like dyes. Those inks are absorbed into the material, and they get part of the material. If yous are printing with a "dye-like ink," and then, instead of ensuring compliance with the "lead in paint" requirements (a 90ppm limit), your garment is probable to be exempt from testing. See 16 CFR 1500.91. If you intend to rely on this materials decision, you must conduct reasonable due diligence with your supplier or manufacturer to ensure the nature of the ink existence used is in fact dye-like ink.
Mostly, CPSC staff differentiates inks, paints, or pigments that finer act like a dye past applying a scraping test. If the ink, paint, or pigment scrapes off then it is considered to be a surface blanket (bailiwick to the pb in paint limit of 90ppm); if it does not scrape off, then it is considered to exist part of the textile itself (bailiwick to the full atomic number 82 content limit of 100ppm). For more than data on the pb in paint requirements, delight visit www.cpsc.gov/leadinpaint.
Inaccessible Component Parts
What does inaccessible mean?
A component part is not accessible if: (1) information technology is not physically exposed past reason of a sealed covering or casing; and (2) does non get physically exposed through reasonably foreseeable use and abuse of the production.
Do paints, coatings, and electroplating make a component part inaccessible?
No. Paints, coatings, and electroplating are not considered to be barriers that would make a component role inaccessible.
If a component part is covered or sealed is it inaccessible?
Yes. A component part of a children'south product is inaccessible to a child if the function is non physically exposed by reason of a sealed covering or casing, and it does not become physically exposed through reasonably foreseeable use and abuse of the product including swallowing, mouthing, breaking, or other children's activities, and the aging of the production, as determined by the Commission.
In addition to passing all applicable use and abuse testing, children's products or component parts of children's products which are enclosed, encased, or covered by textile must measure v centimeters or greater in all dimensions to be considered inaccessible.
How can I tell if the component part is inaccessible?
To assess whether a component will be considered inaccessible, yous should review the technical requirements of the Committee'due south regulation at sixteen C.F.R. §1500.87.
Sure Electronic Devices
Is at that place an exemption for electronic devices in children'southward products?
Yes. To the extent lead is used for the technological feasibility of certain electronic devices for children, such products may be allowed to have a higher lead content in certain component parts. Specific pb limits for such products may be establish in our regulation sixteen C.F.R. §1500.88.
In addition, components of electronic devices that are removable or replaceable, such as battery packs and calorie-free bulbs, that are inaccessible when the product is fully assembled, are not subject to the full pb limits.
Off-Highway Vehicles
Is there an exception for off-highway vehicles?
Yes. Off-highway vehicles are non subject to the total atomic number 82 limits. An "off-highway vehicle" is any motorized vehicle that is manufactured primarily for employ off of public streets, roads, and highways, is designed to travel on two, three, or four wheels, and has either a seat designed to be straddled by the operator and handlebars for steering control, or has a non-straddle seat, steering wheel, seat belts, and roll-over protective structure. The definition also includes snowmobiles.
This provision was enacted by Congress in H.R. 2715, P.L. 112-28 (August 12, 2011).
Bicycles and Related Products
Is at that place a special provision for the metal components of bicycles and related products?
Aye. The metal components of bicycles and related products are permitted to contain upwardly to 300 parts per meg of lead. The list of metallic component parts to which this exception applies is found in the Commission's Observe of Stay of Enforcement Pertaining to Bicycles and Related Products (pdf) published on June xxx, 2009 (74 FR 31254).
This provision was enacted by Congress in H.R. 2715, P.L. 112-28 (Baronial 12, 2011).
Children's bicycles and related products must still exist 3rd party tested and certified as compliant with 16 CFR function 1512. Please see our Wheel Requirements Concern Guidance folio for additional information.
Ordinary Books and Newspaper-Based Printed Materials
Is there a testing exclusion for ordinary books and ordinary paper-based printed materials?
Yes. Ordinary books and paper-based printed materials are excluded from third party testing for lead content.
The term "ordinary volume" means a volume printed on newspaper or cardboard, printed with inks or toners, bound and finished using a conventional method, and that is intended to exist read or has educational value. The term "ordinary paper-based printed materials" ways materials printed on newspaper or cardboard, such as magazines, posters, greeting cards, and similar products, that are printed with inks or toners and jump and finished using a conventional method.
Neither term includes books or printed materials that contain components that are printed on material other than paper or cardboard or incorporate non-paper-based components, such as metal or plastic parts, or accessories that are not function of the bounden and finishing materials used in a conventional method.
The definition does not include books with inherent play value, books designed or intended for a child 3 years of age or younger, and does not include whatsoever toy or other article that is not a book that is sold or packaged with an ordinary volume.
This provision was enacted by Congress in H.R. 2715, P.L. 112-28 (August 12, 2011).
Certain Used Children'southward Products
Is there an exclusion from the full lead requirements for used children'southward products?
Aye. Certain used children's products that were obtained by the seller for use (and not for the purpose of resale) or were obtained by the seller-straight or indirectly-from a person who obtained those products for use (and not for the purpose of resale) are excluded from the total atomic number 82 content requirements. A "seller" includes a person who lends or donates a used children's production.
However, this exclusion does Non apply to children's metallic jewelry, whatsoever children's production for which the donating political party or the seller has actual knowledge that the product is in violation of the atomic number 82 limits, or whatsoever other product or product category that the Commission determines afterwards a discover and hearing. Please run into our Resellers Guide for more than information.
This provision was enacted by Congress in H.R. 2715, P.50. 112-28 (August 12, 2011).
Product-Specific FAQs
Product Packaging
Does packaging have to comply with the lead requirements? Does it thing if the packaging is intended to exist reused (e.g., heavy estimate reusable bag with zipper closure to store a set up of blocks)?
Packaging is generally not intended for apply by children, given that about packaging is discarded and is non used or played with as a children's product. Besides, disposable packaging is not bailiwick to third party testing and certification requirements.
All the same, if the packaging is intended to exist reused, or used in conjunction with the children'south product, such as a heavy guess reusable bag to hold blocks, the bag becomes a component or role of the product and would exist subject to the lead requirements of CPSIA.
It should also be noted that many states accept adopted their own packaging laws that accost toxics in packaging or packaging components that have not been preempted past Commission action.
Arts, Craft, and Science Kits
Are chemical science sets, scientific discipline educational activity sets, and other educational materials excluded from the atomic number 82 content limits for pigment and surface coatings if they bear adequate labeling?
Certain manufactures that are intended for children for educational purposes are exempt for classification as a banned hazardous substance nether the Federal Hazardous Substances Human action (FHSA) (16 C.F.R. § 1500.85) and the lead limits nether CPSIA if: (1) thefunctional purpose of the particular educational item requires inclusion of the chancy substance (unremarkably referred to as the functional purpose exemption); (2) information technology bears labeling giving acceptable directions and warnings for safety employ; and (three) is intended for utilise by children who have attained sufficient maturity, and may reasonably be expected, to read and listen such directions and warnings.
Are children'due south fine art materials subject to the new lead limits?
Aye. To the extent that such art materials are designed or intended primarily for children 12 years of age or younger, they are subject field to the pb limits under the CPSIA.
Moreover, all art materials, whether or not intended primarily for children, must comply with the Labeling of Hazardous Art Materials Act (LHAMA), codification at xvi C.F.R. § 1500.fourteen(b)(8), which requires that art materials be labeled properly if they may present a chronic agin health event. Please encounter our Fine art Materials guidance page for more information.
Outdoor Playground Equipment
Are outdoor playground products required to comply with the full lead limits?
Yes, provided that the outdoor playground equipment is designed or intended primarily for use by children 12 years of age or younger.
Paper and Textile Printing Inks
Is ordinary printing on paper subject to compliance with the total lead content limit?
Yep. Ordinary printing on newspaper is subject to compliance with the total atomic number 82 content requirement of 100 parts per million. However, the Commission, in 16 CFR §1500.91, has determined that paper and other similar materials and CMYK process printing inks normally used in printing on newspaper do not require third party testing for compliance with the lead requirement.
In addition, Congress specifically exempted ordinary books and ordinary printed materials from tertiary political party testing for compliance with the total lead content requirement.
Are textile press inks (screen-printing inks) considered to be part of the product's substrate or a surface blanket?
It depends. Please come across our additional FAQs on textile press inks.
Where can I discover boosted data?
For more information, delight contact the U.South. Consumer Product Safety Committee:
- Starting time, please effort our Regulatory Robot bachelor online at https://business organization.cpsc.gov to find out the applicable requirements for your product.
- Office of Compliance (for specific enforcement inquires): e-mail: section15@cpsc.gov; phone: (800) 638-2772.
- Pocket-sized Business Ombudsman (for general assist agreement and complying with CPSC regulations): e-mail: Please employ our Contact Form, which is the best style to get a fast response; telephone: (888) 531-9070.
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Source: https://www.cpsc.gov/Business--Manufacturing/Business-Education/Lead/Total-Lead-Content-Business-Guidance-and-Small-Entity-Compliance-Guide