Electronic Device Exception to CPSIA Lead Content Limit Rulemaking Update

Congress authorized the CPSC to establish alternative lead limits for electronic devices that cannot feasibly meet the 600 ppm lead content limit currently in effect for all children’s products. On February 12, 2009, the CPSC published an Interim Final Rule to provide certainty regarding exemptions for children’s electronic devices that are in the stream of commerce and fall within the scope of the exemption.

The rule recognizes exemptions for certain lead-containing component parts in children’s electronic devices that are unable to meet the standard CPSIA lead limits due to technological infeasibility and in which the use of lead is necessary for the proper functioning of the component part. Exemptions for lead include: lead blended into the glass of cathode ray tubes, electronic components and fluorescent tubes; lead used as an alloying element in steel (if less than .35% lead by weight); lead used in manufacture of aluminum (if less than .4% lead by weight); and lead used in lead-bronze bearing shells and bushings, among others.

The rule also provides that components of electronic devices that are removable and replaceable, like batteries or light bulbs, and that are inaccessible when the product is assembled and in functional form (or are otherwise exempted) are exempted. Comments on the Interim Final Rule must be submitted to the CPSC by March 16, 2009.

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