The Consumer Product Safety Commission (CPSC) recently announced a major revision to their strict policy on lead limits for products intended for use by children aged up to 12 years and under, making it more important than ever for apparel brands to ensure that their raw material and trim suppliers are using only the safest components under permissible lead limits.
Testing regulations for children’s wear has always been very strict, with focus on lead content, however in a recent development the CPSC has amended Section 101(b) (1) of the Consumer Product Safety Improvement Act (CPSIA) in July 2013, which states that children’s products that are designed or proposed for use by children up to 12 years of age or younger cannot contain greater than 100 ppm (0.01 per cent) of total lead content in any accessible component part of the product.
“According to this new regulation which is mandated by Public Law 112-28, there is exemption of some specific products to comply with lead limits. These products are such which are not normally placed in the mouth by child, and also others taking into account normal and reasonably expected use of these products. This amendment in the regulation is done by taking into consideration that it will not have any adverse effect on public health or safety,” informs Monika Sharma, Head – Softlines & Head – Corporate Sustainability, SGS Group India.
[bleft]CPSC shall grant an exception to the lead content limit for a specific product, class of product, material or component part if after notice and a hearing it determines that:
- It is not practicable or not technologically feasible to manufacture them by removing the excessive lead or by making the lead inaccessible.
- Item(s) are not likely to be placed in the mouth or ingested, taking into account normal and reasonably foreseeable use and abuse by a child.
- An exception will have no measurable adverse effect on public health or safety.[/bleft]
Now, brands need to be very careful of where they source their trims and need to dedicate more time in monitoring restricted substance levels. Some testing agencies inform that this legislation would provide hindrance to production as manufacturers have to be more aware about their raw material, while others believe, “It is going to prove advantageous to the industry but hazardous as well, for which the manufacturers should focus on keeping a check on the lead content through performance testing agencies,” says Paromita Roy, Country Chief Executive, Bureau Veritas Consumer Products Services India Pvt. Ltd.
Meanwhile brands should make sure they are using a trim supplier that has strict restricted substance testing standards. As every product would have a permissible limit of lead content in the garment, it becomes important for the brand to get a certification for the same. Monika states, “The manufacturer or importer of a children’s product that is subject to children’s product safety rules or other standards is always legally responsible for issuing a CPC, even if a third party testing laboratory or another third party provides assistance in drafting the CPC. The CPC must ‘accompany’ the product shipment and be ‘furnished’ to distributors and retailers and upon request; the CPC must be furnished to the CPSC and to the Commissioner of Customs as well.”
Testing companies feel that the amendment is actually more difficult to follow. “Rather than relaxation, the limits have become stricter. For example, limit for lead in surface coating was 600 ppm which is now reduced to 90 ppm, making it more complex for the industry in general but benefiting the end user of the products,” says Suresh Kumar, Senior Vice President, Product Services Division, TÜV SÜD South Asia.
This change to the lead limit policy is a step in the opposite direction by the CPSC in guaranteeing safer products for children. This means that companies can apply for an exception to the lead limit in their products if current technological processes don’t allow for achieving a level of less than 100 ppm. The CPSC will soon outline the procedures for granting an exception in the statute.
