Changes to USA Toy Safety Enforcement Schedule for CPSIA Legislation
Delays in the enforcement of specific provisions have complicated the CPSIA implementation timetable ever since becoming law. Various deadlines have been postponed while the CPSC handles industry concerns, resolves technical challenges and addresses practical considerations.
Summary of recent enforcement changes:
Lead Content in Substrates 100 ppm: August 14, 2011
The law has been amended and this category now applies only to goods manufactured on or after August 14, 2011.
Optional Component Testing: December 8, 2011
New CPSC guidelines took effect on December 8, 2011, which allow the testing and certification of components such as zippers, buttons and blocks to be done by the component manufacturers themselves. This is intended to help spread testing costs along the supply chain.
Lead Ceiling of 300 ppm for Bicycles: January 1, 2012
The stay of enforcement until December 31, 2011 on lead content in bicycle parts has now expired. Metal bicycle components must now have less than a total lead content of 300 ppm.
Mandatory Independent Phthalates Testing: January 1, 2012
Testing for phthalates DBP, BBP, DEHP, DIDP, DINP and DNOP in toys and childcare products must now be performed by a third party on any products manufactured or imported since December 31, 2011. However, testing is limited to any plasticised components that are accessible as a result of normal use or abuse. Inaccessible plasticised components and non-plastic parts are exempt.
Final Independent Testing Requirements: February 8, 2013
The CPSC have now determined final arrangements for mandatory third-party testing and certification of CPSIA requirements that were not already covered by decisions addressing small parts, pacifiers, lead content in surface coatings and metal jewelry for children. These rules come into force on February 8, 2013 and will be applicable for children’s products manufactured on or after that date.
Reasonable Testing Program: On Hold
In May 2010, the CPSC proposed rules for a self-certification program for products not intended for children, but enforcement is delayed.
Small Manufacturer Testing Simplification: Pending
An amendment to the law on August 14, 2011 included a provision authorizing the CPSC to approve simplified testing requirements, or testing exemptions, for manufacturers and importers with up to $1 million in annual gross revenue. No ruling on the availability or feasibility of alternative testing options is forthcoming at present.
About SGS CPSIA Services
SGS’s CPSIA services aim to guide customers, so that their business is clear about the standards it needs to meet and how to achieve them. Because CPSIA regulations are so wide reaching, SGS can create a tailored program for every client, based on their needs and the safety rules they need to adhere to. SGS’s services include consultancy programs and training packages for CPSIA compliance.
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 70,000 employees, SGS operates a network of over 1,350 offices and laboratories around the world.
SGS Consumer Testing Services
Technical Director, Toys
SGS – North America
291 Fairfield Avenue,
Fairfield, NJ 07004, USA
t: +1 973 575 5252 ext. 22038
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