What do toy and children's product manufacturers need to do?

The CPSIA is targeted mostly toward "children's products," which are defined as any consumer product designed or intended primarily for children 12 years of age or younger. If you manufacture products (furniture, toys, garments, etc.) designed for use primarily by children, then it is important that you have a materials testing program in place by a third-party testing laboratory.

Compliance with ASTM F963

Your children's products—and all the parts and components used to assemble your products—need to be in compliance with the new rules on lead, phthalates, and soluble metals content in all materials used for production, including paints and coatings. Your products also need to comply with ASTM F963, "Standard Consumer Safety Specification for Toy Safety," which contains specifications and test methods to determine safety hazards. ASTM F963 specifies over 30 test procedures relating to toy safety and children's product safety. Some of these include:

  • Flammability testing - numerous test methods from simple to complex
  • Toxicology testing - lead analysis and soluble heavy metals
  • Toxicology testing - phthalates di(2-ethylhexyl) (DEHP) also known as dioctyl phthalate (DOP), DnOP, DBP, BBP, DiNP and DiDP
  • Small Objects testing - choke hazards
  • Accessible Edges testing - sharp edges
  • Accessible Points testing -  sharp points
  • Packaging Film testing - thickness and spacing of holes
  • Folding Mechanisms testing - pinch points
  • Cords, Straps testing - choke hazards
CPSIA Testing

The Consumer Product Safety Improvement Act, or CPSIA, requires all children’s products to be tested for total lead, seven additional heavy metals present in the soluble material, and three or six organic compounds by independent testing labs. The law affects manufacturers of toys, bicycles, bed sheets, mattresses, cribs, hair bows, puppets, and virtually anything else a child (under 12 years of age) might come into contact with. The law requires that each accessible part or component of the product be tested. CPSIA is administered by the US Consumer Product Safety Commission (CPSC).

Understanding lead limits in the CPSIA

Lead, which has been banned from paint in the U.S. since 1978, is a neurotoxin that can harm the brain, lower IQ and cause behavioral and learning problems in children. Under the Consumer Product Safety Commission (CPSC 16 C.F.R 1303) regulations, the following timeline applies to regulating lead in children’s products:

  • February 10 2009: Products designed or intended primarily for children 12 and younger may not contain more than 600 ppm of lead. Children’s products that contain more lead than 600 ppm are banned in the U.S. after this date and the sale of those products can result in significant civil and criminal liability. 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. 
  • August 14, 2009: Products designed or intended primarily for children 12 and younger cannot contain more than 300 ppm of lead. 
  • August 14, 2011: Products designed or intended primarily for children 12 and younger cannot contain more than 100 ppm unless the Commission determines that it is not technologically feasible to have this lower limit. 
The CPSIA rules apply to products intended for use by children 12 years or younger and excludes products intended for use by all ages as well as educational materials with a functional purpose (e.g. chemistry sets, electronics kits). It also excludes component parts that are inaccessible to children; with "inaccessible"
meaning it includes a sealed covering or casing (paint, coatings or electroplating are not sufficient).

Testing for other toxic metals

Element lead testing laboratories can also help analyze your materials and products, toys, and children's products for other regulated toxic metals with arsenic testing, mercury testing, cadmium testing, iron testing, and aluminum testing, and others. In addition, Element can test phthalates down to the required regulations needed. 

Support from Element chemists and analytical experts in our testing labs

Element experts are standing by to help you navigate the new and far-reaching regulations. We also encourage you to take advantage of information available on CPSC 16 C.F.R. 1303; the Commission's website.

In today's tough economy and tight regulatory environment, a well-run quality program can make the difference between success and failure. Element experts are committed to helping you and your products meet the standards you need to succeed. Let us provide you with critical lead testing data and certification for your products and parts.

  • 16 CFR Part 1303
  • 16 CFR Part 1508
  • 16 CFR Part 1509
  • ASTM D1230
  • ASTM F 963
  • EN 55014-1

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