Manufacturers of Consumer Products

Hazardous content in consumer products has become a growing concern. Governments are enacting new regulations to boost consumer confidence and provide a measure of safety for these products.

Numerous new amendements to laws have been enacted, companies need to be aware of what it means to the products they make / import and to their business. The most prominent of these consumer products are those for children under the age of 12.

Regulations of Interest

(CPSIA) Consumer Product Safety Improvement Act of 2008
- To establish consumer product safety standards and other safety requirements for children’s products and to reauthorize and modernize the Consumer Product Safety Commission.
ASTM F 963
- This specification relates to possible hazards that may not be recognized readily by the public and that may be encountered in the normal use for which a toy is intended or after reasonably foreseeable abuse. It does not purport to cover every conceivable hazard of a particular toy.
BSI BS EN 71-3
- This part of this European Standard specifies requirements and test methods for the migration of the elements antimony, arsenic, barium, cadmium, chromium, lead, mercury and selenium from toy materials and from parts of toys except materials not accessible (see part 1 of this standard).

Rulings & Updates

Accreditation of 7 Laboratories as "Firewalled" 3rd-Party Conformity Assessment Bodies, July, 2009
- The staff recommended that the following laboratories be accredited for the requirements and test methods indicated.
CPSC: SOP for Determination of Phthalates (02.09.09)
- CPSC staff has concluded that these test methods are sufficient to determine the concentration of the 6 regulated phthalates in most consumer products.
Phthalates Ruling: Memorandum Opinion & Order: National Resources Defense Council v. CPSC
- Section 108 of the CPSIA, entitled “Prohibition on sale of certain products containing specified phthalates,” establishes a framework for the federal regulation of children’s toys and child care products containing phthalates.
Proposed Revision of ASTM F963-07, May 2009
- On February 17, 2009, ASTM officially proposed replacing the current consumer product safety rule, F 963-07e1 with F 963-08.
Statement of Commission Enforcement Policy on Section 101 Lead Limits (02.06.09)
- In section 101, Congress made clear that the lead limits apply not only to products manufactured after the effective date, but also to products manufactured earlier (pdf). In August, these limits will drop to 300 ppm.