Testing Substrates

Section 102 of the CPSIA amended the Consumer Product Safety Act (CPSA) requires manufacturers to certify their products to demonstrate compliance with the CPSC's rules, standards, or bans. This involves implementing and adhering to a reasonable testing program. Part of that reasonable testing program is to perform compliance testing of any and all paints and coatings, but also to incorporate the testing of any and all applicable material substrates.

The CPSIA establishes specific lead limits in children’s products. Section 101(a) of the CPSIA states that, as of August 14, 2009, products designed or intended for children 12 and younger cannot contain more than 300 ppm of lead. On August 14, 2011, that limit may be reduced to 100 ppm, unless the CPSC determines that it is not technologically feasible to meet that lower limit. Paint, coatings or electroplating are not considered a barrier that would make the lead in substrates accessible.

The CPSC staff has identified materials whose lead content is consistently below the limit of 300 ppm. These include certain natural materials, such as wood, cotton, and wool, as well as certain metals and alloys. Other exempt materials include: precious gemstones and semiprecious gemstones; natural or cultured pearls; wood; paper and similar materials; traditional CMYK process printing inks; textiles of natural fibers; some manufactured fibers; other plant-derived and animal-derived materials; surgical steel and other stainless steel; and precious metals. But any textiles that have undergone after-treatment applications, such as screen prints, transfers, decals, or other prints still need to be certified for compliance. Contact our staff here at ATS for further details on those materials requiring compliance testing.

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