Consumer product safety lead regulations for children’s products

IPC comments seeking clarification on requirements of new consumer product safety law pay off.

Feb. 11, 2009

by Tam Harbert

Certain electronics products intended for children are exempted from the Consumer Product Safety Improvement Act (CPSIA) lead limit as of Feb. 10, 2009. The act, a comprehensive overhaul of consumer product safety laws, was enacted in response to well-publicized recalls of imported toys with lead paint. Under the CPSIA, the lead content in products intended for children is required to be no greater than 600 parts per million.

The Consumer Product Safety Commission (CPSC) issued an interim rule effective immediately because the Jan. 15, 2009, proposed rules already under consideration would have been finalized after the Feb. 10 CPSIA compliance deadline. The CPSC’s interim rule and the Jan. 15 proposed rules clarify that lead contained within electronics parts is inaccessible to children.

Lead Provisions
As a result of IPC’s efforts, the CPSC’s interim rule and the Jan. 15 proposed rules clarify that the lead contained within electronics parts is indeed inaccessible to children. The CPSC has recognized that lead in component parts of electronic devices are not accessible to children because the lead is fully enclosed within the components that are themselves within the electronic device.

Because the CPSC now considers parts contained in electronic products inaccessible by children, the interim rule exempts electronic components within children’s products from the lead level requirements of 600 ppm.

In comments to the CPSC, IPC, in conjunction with the Information Technology Industry Council (ITI) and the Consumer Electronics Association (CEA), pointed out that the European Union’s Restriction of Hazardous Substances (RoHS) directive already severely restricts the use of lead, establishing a maximum concentration value of 1,000 ppm per homogenous material in electronics, but also grants exemptions where there are no technically feasible or environmentally preferable substitutes.

“IPC efforts averted a major market disruption for anyone wanting to sell children’s electronic products to American consumers.” Chamrin says. “The CPSC’s interim ruling that lead contained within electronics parts is inaccessible to children means that electronics manufacturers do not need to address their design and fabrication process to ensure compliance with CPSIA lead restrictions.”

IPC, ITI and CEA suggested the CPSC use RoHS as a guide and that the lead limit for accessible parts be set at 1,000 ppm. The group also stressed that electronic components were inaccessible under CPSIA definitions. IPC has been effective in conveying these messages to CSPC, Chamrin says.

IPC in conjunction with ITI and the CEA will be providing comments on the 2009 proposed rules to reiterate the industry’s support for these necessary exemptions.

Certifying Compliance
Finally, CPSIA expanded requirements for self-certification and testing of products that are subject to any rule, ban, standard or regulation enforced by the CPSC. The new CPSIA regulations require manufacturers to certify compliance to the CPSC regulations with every consumer product shipment beginning Nov. 12, 2008.

In the case of electronics that are deemed children’s products, this means final product manufacturers may request certification from all their suppliers, including PCB manufacturers. Originally, the CPSC was going to require paper certificates be printed and shipped with each product, which was not feasible for component and circuit board suppliers, Chamrin says. The agency subsequently agreed that Web-based certification would be adequate.

For more information on CPSC regulations and guidance, please visit or contact Ron Chamrin, IPC manager of government relations at +1 703-522-0225 or