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CPSIA (Consumer Product Safety Improvement Act): HR4040
The Consumer Product Safety Improvement Act (CPSIA) was written to improve the current statute of the Consumer Product Safety Act. It was enacted "to establish consumer product safety standards and other safety requirements for children's products and to reauthorize and modernize the Consumer Product Safety Commission".
This is a landmark regulation that covers many children's products from books to clothing to toys and everyday items manufactured and marketed for children's use.
Under the CPSIA, the films we produce targeted for later use in the manufacture of children's products have been subject to the following requirements:
1. Lead In Substrate Compliance
The CPSIA introduces the following limits for lead in substrate:
| August 14, 2009: |
Limits Total Lead Content to 300ppm for products manufactured AFTER February 10, 2011.
General Certificate of Conformity and Accredited andThird Party Test will not be required till Feb. 10, 2011 due to an extension on the Stay of Enforcement. |
| August 14, 2011: |
Limits Total Lead Content to 100 ppm
(if technologically feasible)
General Certificate of Conformity and Accredited
Third Party Test required at that time. |
| Test Method: |
CPSC-CH-E1002-08
Standard Operating Procedure for determining Total Lead in Non-Metal Children's Products.
http://www.cpsc.gov/ABOUT/Cpsia/CPSC-CH-E1002-08.pdf | |
2. Phthalates Compliance
The following phthalate limits are applicable to plasticized component parts of a children's product or article as defined by the CPSIA:
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CPSIA (HR 4040) GROUP 1 |
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BBP (Benzyl Butyl Phthalate)
DBP (Dibutyl Phthalate)
DEHP (Di-(2-ethylhexyl) Phthalate) |
Banned in ALL toys and childcare articles
For children up to 12 Years of age
Limit set of 0.1% concentration per phthalate per plasticized component of each product.
Permanent Ban | |
|
CPSIA (HR 4040) GROUP 2 |
|
DIDP (Diisodecyl Phthalate)
DINP (Diisononyl Phthalate)
DnOP (Di-n-octyl Phthalate) |
Banned from use in ALL toys and childcare articles intended for children under three (3) yrs of age that can be put in children's mouths
Limit set of 0.1% concentration per phthalate per plasticized component of each product.
Interim Ban | |
| The General Conformity Certificate and Accredited Third Party Test has been given an extended Stay of Enforcement and will NOT be required until 90 days after the Commission issues notices of accreditation of laboratories for testing. |
| Test Method: |
CPSC-CH-C1001-09.2 Standard Operating Procedure for Determination of Phthalates.
http://www.cpsc.gov/ABOUT/Cpsia/CPSC-CH-C1001-09.2.pdf | |
Please note that though the Stay of Enforcement has been extended for the submission of the accredited Third Party Tests and General Conformity Certificates, the CPSC maintains the requirement for compliance as effective immediately.
What are phthalates anyway?
Phthalates are esters of phthalic acid primarily used as plasticizers. It is most commonly added to soften Polyvinyl Chloride (PVC) polymer though its use is not limited to this.
Do ALL plastics contain phthalates?
No, they do not. Phthalates are more commonly found in flexible PVC products signified by the SPI marking below.
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PVC
Some Type 3 Plastics may leach Bisphenol A | *The Society of Plastics Industry (SPI) marking is used to identify a product for recycling and does NOT indicate product bearing this mark automatically contain phthalates.
Rigid plastics do not normally contain phthalates.
PVC Tech Corp and the CPSIA
No, we don't make toys or children's products, but our films are often used as components of final products manufactured and marketed for children.
We carry a range of CPSIA compliant flexible materials complete with the required accredited third party test reports certifying test results to both lead in substrate and phthalate restrictions under this regulation. Our Rigid Materials do not typically use phthalates as certified by our manufacturers.
Though the Consumer Product Safety Commission (CPSC) has extended the Stay of Enforcement thereby alleviating the need to furnish general conformity certificates and the third party test reports (February 11, 2011 for Lead in Content or 90 days after the Commission issues notices of accreditation for laboratories for testing for phthalates), PVC Tech has chosen to provide these tests on all our CPSIA compliant phthalate-free materials prior to this date to give our customers peace of mind and the assurance that our films are safe to use for child product applications regulated by the CPSIA.
All tests are furnished by CPSIA accredited labs only and available upon request.
This summary is non-legally binding. It has been published as an overview of the subject headed for purposes of summary review and does not replace the obligation of individual companies to identify, review and understand the subject and/or regulations discussed and its implications on their organization.
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