CPSC Clarifies Rule on Component Part Testing
The Consumer Product Safety Commission (CPSC) published a direct final rule amending two rules on component part testing and lead in textile products in October 2015. The rule has been effective since January, but the CPSC recently provided clarification on the two rules.
1. Clarification on Component Part Testing (16 CFR 1109):
- In order to reduce burden of testing on manufacturers, on Dec. 8, 2011, CPSC enacted final rule 16 CFR 1109 allowing manufacturers to certify final products based on component part testing or testing by another party.
- Subpart A of this rule provides the general condition and requirements for component part testing, and subparts B and C provide additional requirements for specific products, component parts and requirements. As the requirements in the subparts B and C are limited to lead and phthalates, some parties have misinterpreted the component part rule as limited to just these two substances only.
- This amendment clarifies that component part rule is not limited to lead and phthalate testing. It also may be used for other test wherever applicable, such as heavy metals, mechanical and performance tests that can be performed at the component part level of a product.
- The amendment also replaces the old version of reference standard ASTM F963-08 with the latest version ASTM F963-11.
- Section 1109.13 also has been updated, adding the information that inaccessible components do not need to be tested for phthalate content.
2. Clarification of the Textiles to be considered not to exceed lead limit (16 CFR 1500.91):
- In the rule 16 CFR 1500.91, CPSC excludes certain materials and products from lead requirement considering that these materials, by nature, do not contain lead exceeding permissible limit (90 ppm for coatings and 100 ppm for substrates).
- Section 1500.91(d)(7) states exemption applies to “textiles (excluding after-treatment applications, including screen prints, transfers, decals or other prints) consisting of [various fiber name].” The CPSC has found that the phrase ‘or other prints’ may be wrongly interpreted to mean that the application process of print is a determining factor for the exemption. In this amendment, "example of printing" has been removed, clarifying that textiles with or without having an application which entirely consist of dyes are not required for testing for lead content. Hence, dyed and printed textiles where dyes are embedded into the textile fiber are excluded from testing. However, in case of print where other material is added, for example plastisol print which contain plasticizer and PVC, are not excluded from lead requirement.
For more information on CPSC, visit www.cpsc.gov.