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How to Reduce Compliance Costs

There are two primary methods for reducing the cost of compliance to US toy safety regulations: (1) the component parts rule, and (2) determinations.

Components Parts Rule

The component parts rule is useful to nearly all manufacturers that utilize surface coatings or who use a single component on multiple products. The rule allows for heavy metals compliance for a finished good when all of the components can be shown to be compliant.

Utilizing this rule requires managing your supply chain and record-keeping that allows traceability from finished good to compliant component part.

In October of 2015, the CPSC issued an amendment to clarify when the component parts rule can be used.

Determinations

Determinations can be used to significantly reduce cost when natural materials like wood, paper board, and cotton fabrics are part of a finished good. The CPSC has promulgated several rules indicating that some materials in their natural state do not contain heavy metals or phthalates and therefore do not need to be tested.

  • Determination regarding lead in some materials
    Effective August 28 2009, This determination indicates that certain materials do not include lead in excess of the statutory limits and therefore do not require third party testing. These materials include: gemstones, wood, paper, CMYK inks, certain textiles like cotton, certain manufactured fibers like polyester and nylon, animal and plant based materials, and certain metals and alloys.In October 2015, the CPSC issued an amendment to clarify which textile products are determined not to contain lead.Note that this early determination does not include the additional heavy elements included in ASTM F963.
  • Determination regarding heavy elements limits for unfinished and untreated wood
    Effective January 19 2016, the determination indicates that unfinished and untreated trunk wood does not contain heavy elements that exceed the limits specified in ASTM F963-11. Based on this determination, unfinished and untreated trunk wood in toys do not require third party testing.
  • Determination regarding certain engineered wood products
    Effective July 23 2018, the determination indicates that certain untreated and unfinished engineered wood products (EWPs), like particleboard, hardwood plywood, and medium-density fiberboard do not contain lead, the ASTM F963 heavy elements, or phthalates that exceed the statute limits. Based on these determinations, these EWPs do not require third party testing.
  • Determination regarding phthalates
    Effective January 26 2018, (with typographical correction on July 23 2018,) the┬ádetermination indicates that certain plastics with specified additives do not contain the specified phthalates prohibited in children’s toys and child care articles. Based on these determinations, the specified plastics do not require third party testing for compliance.

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