If You Sell Promotional Products, Learn to Read a Test Report
Labs only perform the tests that they're asked to perform, just as in the stuffed toy example. So if you see a report with a passing lead test, look closely to see what it is covering. CPSIA requires two different lead tests. The first is for lead in the material itself - sometimes called total lead or lead-in-substrate. (The actual wording in CPSIA is "total lead content by weight for any part of the product.") That limit is currently 100 ppm for children's products. The second requirement is for lead in any paint or surface coating. That could either be a painted surface of the product itself or the imprint/applique that the supplier or decorator applies. Normally ink used for printed material like books and catalogs is considered part of the material. But heat transfers, pad printing and silk screening inks—particularly if they can be scraped off—are usually considered surface coating. The lead limit for paint and surface coating is 90 ppm. So you need a test for the lead in the material and a separate test for lead in any surface coating. The lead in material test is usually labeled on a test report as something like "CPSIA Lead in substrate." The lead in surface coating test is usually labeled 16 CFR 1303 for the section number of the Code of Federal Regulations (CFR) containing the regulation.
Bullet point five: European standards are for Europe. US standards are for the US. They aren't the same. If you see a passing test report for EN71—the European toy safety standard—don't assume that the product will pass ASTM F963—the US toy safety standard. They're different.
Bullet point six: If your product happens to be a toy, it needs to comply with the the Federal Toy Safety Standard usually referred to as ASTM F963. This used to be a voluntary standard but in CPSIA—the Consumer Product Safety Improvement Act—Congress made it mandatory. ASTM F963 isn't one test—it's 67 pages of various tests for which toys need to comply. If you drop the toy from three feet will it shatter? Is it a choke hazard? Does it have sharp edges? Lots of things like that. So if your product is a toy, be sure that the report states that it is fully compliant with all applicable tests from the current ASTM F963 standard. Most labs will do that automatically but remember our battery compartment experience.