The CPSIA sets several new requirements for toys and children’s products in addition to requiring compliance documentation and transforming ASTM F963-07e1 into a mandatory safety standard. MSR can help you through the entire spectrum of CPSIA requirements, from assisting you with your compliance documentation, to performing the lead and phthalate testing or physical/mechanical testing per ASTM F963-07e1 to advising you on labeling requirements, applicability and the myriad other questions raised by this new legislation.

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Lead in Substrates: All accessible substrates of children’s products must not contain more than 600 ppm total lead starting on February 10, 2009. Since congress has declared items that do not meet this requirement are a “banned hazardous substance”, this requirement is retroactive and no product may be offered for sale after this date, regardless of when it was manufactured. The statute provides that paint, coatings or electroplating may not be considered a barrier that would make the lead content of a product inaccessible to a child.

On August 14, 2009, the lead in substrates requirement will be lowered to 300 ppm total lead. Again, this will apply to all products on the shelves, using the reasoning as outlined above. On August 14, 2011 the lead in substrates requirement will be lowered to 100 ppm total lead. If it is determined the 100 ppm is not technologically feasible, the new requirement will be at a level between 100 and 300 ppm, depending on what is determined to be feasible. Again, this will apply to all products on the shelves, using the reasoning as outlined above.

Lead Paint Ban: On August 14, 2009, the ban on lead in paints and surface coatings as defined in 16 CFR 1303 will have the total lead limit lowered from 0.06% (600 ppm) to 0.0090% (90 ppm). Once again, this will apply to all products on the shelves, using the reasoning as outlined above.

One issue that should be addressed is compositing of test samples – that is, combining more than one color of paint/substrate material and testing for lead as a single sample. While this is common as a money saving procedure, the CPSC has ruled that this is not acceptable for the purposes of meeting the requirements of the CPSIA (see http://www.cpsc.gov/about/cpsia/faq/101faq.html)