CPSC To Begin Enforcing Third-Party Testing On Lead Levels For Children’s Products

As of January 1, 2012, the Consumer Product Safety Commission (CPSC) will require manufacturers and importers to provide third-party testing and certification of children’s products for compliance with limits on total allowable lead content. These regulations are pursuant to Consumer Product Safety Improvement Act (CPSIA) requirements.

The CPSC’s required third-party testing and certification that goes into effect on January 1, 2012, limits the total allowable lead content in children’s products to 100 parts per million. For more information about the total lead limits in children’s products, please visit the CPSC website.

The following product tests will require third-party testing after December 31, 2011:
• Lead content in children’s metal products*
• Lead content in children’s non-metal products*

The CPSIA has stated that all children’s products will require third-party testing by CPSC-approved laboratories. Because the CPSC must publish lab accreditation requirements for product tests before they are made mandatory, the aforementioned goal has not yet been fully met. The following product tests currently require third-party testing by a CPSC-approved laboratory:
• Lead in paint
• Small parts
• Lead in children’s metal jewelry
• Flammability of clothing textiles
• Flammability of vinyl plastic film
• Flammability of children’s sleepwear (sizes 0-6x and 7-14)

The following product tests will require third-party testing 90 days after the CPSC publishes the lab accreditation requirements:
• Phthalates*
• Small balls/marbles*
• Toys (ASTM F963)*

All children’s product safety rules generally include third-party testing and certification requirements. To achieve certification, manufacturers and importers of children’s products must produce a written Children’s Product Certificate (CPC) for each product. The CPC identifies the product, the applicable rules or compliance standard, the third-party laboratory where it was tested and other requirements. Certification must be based upon the results of third-party testing—testing performed by a third party, accredited laboratory accepted by the CPSC to perform specific tests associated with children’s product safety rules.

*Compliance to these standards is required. General Conformity Certificates (GCCs) are required if third-party testing is required. GCCs are not required if third-party testing is not yet required but compliance is still mandatory. GCCs are also required for certain non-children’s products such as the flammability of clothing textiles standard.