CPSIA Policy Statement

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Policy Statement Regarding Compliance with the Consumer Product Safety Improvement Act (CPSIA)

The vast majority of product distributed and sold by _____________ is designed for and intended for use by adults and children over the age of 12 years. Nonetheless, _____________ is, and will continue to be, in compliance with all aspects of the newly enacted CPSIA.  The list below is not comprehensive, but is provided as an overview of the critical dates and regulations of the CPSIA that __________ complies with.

November 12, 2008

General Conformity Certificates are required for consumer products subject to a standard, ban, rule or regulation under the jurisdiction of the CPSC and which are manufactured on or after November 12, 2008.  The certificates indicate compliance with all effective standards, bans, rules and regulations under the jurisdiction of the Consumer Product Safety Commission (CPSC). These certificates will be made available to all retailers and distributors.

December 21, 2008

Third -party testing at a CPSC-accredited lab for lead paint and surface coatings in accordance with 16 CFR 1303 for children’s products is required effective December 21, 2008.  The lab will provide testing reports certifying that the products meet the applicable lead content and lead in paint provisions.  Compliance with these provisions will, after December 21, 2008, be indicated on the General Conformity Certificates.

February 10, 2009

Phthalates:    Children’s  toys or child care articles manufactured on or after February 10, 2009 with concentrations of 3P phthalates in excess of 1000 ppm (parts per million) or children’s toys or child care articles that are mouthable (as defined by the CPSIA) with concentrations of 6P phthalates in excess of 1000 ppm  are banned.

Lead: The lead content ban takes effect for the sale of children’s products with concentrations of lead in substrates in excess of 600 ppm.

Currently, third party testing and certification pertaining to both phthalates and lead are stayed until February 10, 2010.

February 15, 2009

Small parts: All new advertisements (including in catalogs and online) for children’s products subject to small parts regulations must contain cautionary warnings similar to those posted on product packaging.  (Any materials already printed before February 15, 2009 may be distributed until August 2009 without such additional warnings.)    The stay does not apply to this requirement.

August 2009

Children’s products must contain tracking labels or date codes designed to identify products in the event of a recall.

Ban takes effect on sale of children’s products with concentrations of lead in substrates in excess of 300 ppm and in lead paint in excess of 90 ppm and third-party testing required for certification.

California

In addition to and independent of the above requirements, beginning on January 1, 2009, AB1108 prohibits the sale in California of 1)  children’s products with 3P phthalates in concentrations greater than 1000 ppm.  2) any toy or child care article for use by children under three years of age with 6P phthalates in concentrations greater than 1000 ppm if the product can be placed in a child’s mouth.

Should you have any questions regarding this statement, please contact __________________ at ______________________.