Consumers Product Safety Improvement Act of 2008
On August 14, 2008, President Bush signed into law the Consumer Product Safety Improvement Act of 2008 (CPSIA). The legislation was passed in response to many high-profile recalls of both imported and domestically-produced children’s toys due to excessive levels of lead and other possible toxic chemicals in children’s toys.
The new law establishes three requirements that are relevant to printing operations and their customers and they are:
- Testing and certification of compliance for lead content in all children’s products. (see one-year "stay" below)
- Testing and certification of compliance for certain phthalates in certain children’s products. (see one-year "stay" below)
- Inclusion of “tracking labels” on all children’s products.
When does the CPSIA apply to books?
The CPSIA requires printers to test and certify that their products comply with new lead and phthalate content limits established by the CPSIA. For children’s products/books, a formal Compliance Certificate must be issued by the printer and accompany all products manufactured on and after February 10, 2010.
What is a children’s book:
The term “children’s book” is broadly defined by the CPSC, as a “consumer product intended primarily for children 12 years of age or younger” and included such items as children’s books.
What Lead Content Limit does the CPSIA Establish?
CPSIA bans the manufacture, sale, and distribution of any children’s product, including any existing product in inventory, that contains more than 300 parts per million by weight (ppmw) total lead content. The CPSIA may reduce the lead limit again in August 2011 if it can be shown that it is technically feasible on a product-by-product basis.
What Phthalate Content Limits does the CPSIA Establish?
The CPSIA created limits applicable to children’s books. A permanent ban on the manufacture, sale, and distribution of children’s toys or child care articles containing more than 0.1% phthalate (BBP)
What Testing Is Required to issue a Compliance Certificate?
The CPSIA requires by an accredited third party laboratory. As of August 21, 2009, the CPSC has not issued accreditation guidelines for total lead or phthalate content testing in products. When CPSC accredits labs for lead in children’s products or phthalates, they will be identified at this web site.
Are there any Exemptions from the Testing and Certification Requirements for Lead?
On August 19,2009 the CPSC issued its first in what is hoped a series of determinations regarding books and other printed matter exemptions for the lead limits. The commission addressed some components of books and other printed materials. The components of books that are now exempt include the following:
- Paper
- Four color process inks (CMYK)
- Varnish, water-based, or UV-cured coatings
- Animal based glues
- Adhesives that are not accessible
The materials that are NOT covered by the current determination are:
- PMS inks
- Stitching wire
- Plastic coils for coil bound materials
- Foils used in foil stamping
- Laminates
What does the CPSC’s “One-Year Stay of Testing and Certification Requirements for Certain Children’s Products” do?
On January 30, 2009 the CPSC issued a one-year stay of the testing and certification requirements for certain children’s products including books. See: CPSIA letter to customer on one-year stay.
In December 2009 the CPSC issued and extension of the above stay. The commission extended the stay of testing for total lead content as required by the CPSIA to February 2011.
What are the Tracking Label Requirements of the CPSIA?
Effective August 14, 2009 the CPSIA requires manufactures of children’s product to place permanent, distinguishable marks on the product and it’s packaging that identify the manufacturer, date and location of product production, and any identifying batch or other run characteristics.
The CPSC does not have a uniform “one-size-fits all” approach and is not specifying what they should look like or appear on the product. They do mandate distinguishing marks that identify:
- Manufacturer
- Location of production
- Date of production
- Run number
Dickinson Press CPSIA Letter of Compliance
For more Information: Brief summaries of the changes and other supporting information can be found on the Printing Industries of America’s CPSIA website at www.printing.org/cpsia
