CPSIA- jcaroline creative

CPSIA: Manufacturers using our products in children's items

Items for children under 12 may not contain more than 600 ppm in lead, but the CPSC (Consumer Product Safety Commission) is still in flux as to how a manufacturer, reseller or importer prove that their item meets the lead limits. The agency has said they will issue guidance over the course of the next year.

Please note that I am focusing ONLY on the requirement that items for children under 12 contain less than 600 ppm in lead. We are not attempting to address the phthalates issue or other requirements under the act. First, I don't know enough about it and it does not appear to apply to most of what we sell. If you are unsure about the other requirements under the Act and their application to your product, I encourage you to consult with a CPSIA expert.

My second disclaimer is that I am only concerned about the metal items and vinyl that we sell. I believe it is highly unlikely that any of our "textile" products- fabric, ribbons and trims-- contain lead. I also believe they are not required to be tested at this time. I formed this opinion based on CPSC's guidance that they would not impose penalties on manufacturers, resellers or importers using

  • "a children's product to the extent that it is made of certain natural materials, such as wood, cotton, wool, or certain metals and alloys which the Commission has recognized rarely, if ever, contain lead; "
  • "dyed or undyed textiles (not including leather, vinyl or PVC) and non-metallic thread and trim used in children's apparel and other fabric products, such as baby blankets."

In the meantime, I am working with the manufacturers of our metal products to provide you with a level of confidence that the component items you are purchasing from us meet the new lead limit. Since the CPSC's requirements for evidence have not been finalized yet, I can provide no assurance that the evidence that our manufacturers will provide will be in compliance. However, our goal is to provide you confidence that the items you are purchasing meet the lead limits.

Documented Items

For the following items, the manufacturers or importers have provided me with documentation of their compliance with the lead levels (documentation available by clicking on the link):

Items Awaiting Documentation

I have contacted the manufacturers and they have verbally told me that they do not believe their products contain lead and that they are working on providing either testing data or information about their manufacturing process that would provide assurance that lead is not a component. I will provide their documentation as soon as I receive it.

  • Bobby Pins
  • Zipper Pulls
  • You Cover Buttons
Current Unknowns
  • 12 Guage Vinyl (waiting for word from the manufacturer- lead can be used to stabilize vinyl)
  • Metal Snap Tape
  • Metal Buttons
  • Metal Hardware
If there is a specific item of concern to you that is not listed above, please let me know and I will gather any information that I can.

As more guidance is issued by the CPSC, I will do my best to inform you of what the evidential requirements are and help you comply.

Caroline Devoy

Updated 2/12/2009
CPSIA Information for Manufacturers
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