Selling products that will be used by children.


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I just read a blog post about the law that was passed in 2009 that all things to be used around children under the age of 14(toys,cribs, etc) must be certified lead free in order to sell yet I've never seen this posted anywhere on sites that sell these things. Do people just simply ignore this law?

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Sort of. There are things that dont need to be certified and we are talking only lead certification under CPSIA 2008 safety is a whole other issue. For example if you sold wooden rubber band guns. If sold as unfinished the wood itself does not need to be certified for lead content under 300ppm. If you painted the rubber band guns only the paint would need to be certified. The paint is usually certified by the manufacturer (using a third party) eliminating the need for any certification by the guy that makes rubber band guns.

Make sense?

Don

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It is my understanding that if the product you are making is for use by a child 12 or under and it is made entirely of Wood or other specific natural materials no testing or certification is required. However, if the product has a finish coating testing and certification is required. In addition, if the product contains components that may contain phthalates, testing and certification is also required.

I do not believe you can use component testing (testing by the paint mfg for example). The Hand Made Toy Alliance website www.handmadetoyalliance.com has as good an explanation as I can find.

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It is my understanding that if the product you are making is for use by a child 12 or under and it is made entirely of Wood or other specific natural materials no testing or certification is required. However, if the product has a finish coating testing and certification is required. In addition, if the product contains components that may contain phthalates, testing and certification is also required.

I do not believe you can use component testing (testing by the paint mfg for example). The Hand Made Toy Alliance website www.handmadetoyalliance.com has as good an explanation as I can find.

That's what I thought so unless you don't want to finish it you pretty much have to get it tested in order to sell it.

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An example direct from the commission. Component parts are being tested individually you do not have to test the full product. To test the entire finished product would insane especially since manufacturers may use the same components in many products.

2. A children’s coat, size 6x, is made of a variety of fabrics and a zipper. The

fabric does not need to be tested for lead content because textiles are on the

list of materials and products we have determined to not contain lead above

the 100 ppm limit. The lead content of any plastic, metal, or painted parts of

the zipper, however, would need to be tested to verify that they do not exceed

the lead limits. A zipper may consist of several parts including the zipper

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I just asked my wife to contact the commission directly since they are the legal authority. Their council made it pretty clear that component testing will be cleared up by the time testing takes affect. Sounds as if its probably going to be put off for another year. As of right now its the end of this year and the bugs still are not worked out. As of right now its written to allow component testing or very un clearly allow component testing. Right now any information that does not come directly from the commission is just hearsay and half of that that comes from the commission itself is hearsay until the final documents have been approved. I doubt it will be finalized by the end of this month.

Don

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Note that even if no finish is applied to the toy, metal parts (screws, nuts, bolts, etc.) as well as glue would have to be tested if they will allow component testing. As far as I can tell, it is not clear that they will allow component testing.

So if you turned a wooden top from one piece of wood you would be good to go if you didn't put a finish on it. If you glued up the wood, testing may be required.

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Note that even if no finish is applied to the toy, metal parts (screws, nuts, bolts, etc.) as well as glue would have to be tested if they will allow component testing. As far as I can tell, it is not clear that they will allow component testing. So if you turned a wooden top from one piece of wood you would be good to go if you didn't put a finish on it. If you glued up the wood, testing may be required.

Sort of but not always the case. Its all about accessibility. Here is another quote from the commission.

1. A book made with a cardboard cover glued to pages made with paper and

printed with CMYK process printing inks does not need to be tested for lead

content and no certificate is required by the Commission. The paper,

cardboard, and CMYK ink are all on the list of materials and products that we

have determined not to contain lead above the 100 ppm limit, and the glue

used for binding is inaccessible. If, however, the book was bound with metal

spiral binding rather than inaccessible glue, the metal spiral bindings would

need to be third party tested for compliance with the 300 ppm lead content

limit, and the product would need to be certified. If the metal spiral binding

was painted, in addition to testing the metal spiral binding for lead content, the

paint also would need to be tested to assure that it complies with the 90 ppm

lead in paint limit and certified as complying with that standard as well.

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