CPSC Adopts New Flexibility for Testing of Component Parts for Lead

The Consumer Product Safety Commission (CPSC) voted unanimously this month to adopt an interim enforcement policy allowing component part testing for lead. Under this policy, manufacturers and importers can certify their products as meeting lead paint and lead content limits in the following ways:

Lead in Paint

• Have test reports from recognized independent third party testing labs showing that each paint on the product complies with the 90 ppm lead paint limit.

OR

• Have certificates from paint suppliers declaring that all their paint on the product complies with the 90 ppm lead limit based on testing by recognized independent third party testing laboratories.

Lead content

• Have test reports from recognized independent third-party testing labs showing that each of the accessible component parts on the product complies with the 300 ppm lead limit.

OR

• Have certificates from part suppliers declaring that all accessible component parts on the product comply with the 300 ppm lead limit based on testing by recognized independent third party testing laboratories.

Most fasteners, such as buttons, zippers, and screws, sold by themselves are not considered children’s products and would not have to comply with the lead limits or be certified. However, the same fasteners must meet the lead limits if they are used on a children’s product. Voluntary certification by suppliers of component parts would make them more beneficial to manufacturers who use them in children’s products.

Note, any person who issues a false certificate is subject to penalties.

While the stay of enforcement remains in effect for the certification and testing requirements for certain products, all products must comply with the safety standards and bans of the law, including the limits for lead content, lead paint, the ban on certain phthalates and the ASTM F-963 mandatory toy standard.

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