Total Lead Content in Accessible Children’s Product Components

Accessible components of products designed or intended primarily for children 12 or younger must not exceed 100 parts per million total lead, subject to applicable statutory provisions. Identify the substrate materials and accessible parts in the finished article. A heavy lead-free component cannot be used to dilute the result for another component that exceeds the limit.

The statutory treatment of inaccessible components is implemented through the relevant CPSC provisions, including section 1500.87. Consider foreseeable use, abuse and aging conditions rather than whether a component is visible on a showroom sample. A coating, plating or paint layer is not automatically a durable barrier that renders the underlying material inaccessible for lead-content purposes.

Section 1500.91 identifies certain materials or products determined not to exceed the lead limit when the stated conditions hold. This can affect the need for testing; it is not permission to add lead-containing treatments or rely on an unchanged material name after processing. Record composition, finishes and supplier information supporting the particular determination being claimed.

Where testing is required, select a CPSC-accepted laboratory for the applicable lead-content scope and use the appropriate substrate method. Distinguish metal, nonmetal and coating samples in the report. Component-part testing may support certification under part 1109 when its conditions are satisfied. Keep sample identity, analytical method, result, unit and any applicable testing determination with the product record. Do not pool dissimilar components merely to obtain a lower reported result.

Lead paint and similar surface coatings have a separate 90 ppm requirement under part 1303. A substrate result below 100 ppm does not establish that the paint passes, and a paint result does not establish that the plastic or metal beneath it passes. Printed decoration, plating and other treatments require classification according to the relevant definitions rather than an informal surface-versus-core distinction.

Use the material map to identify which report or determination covers each accessible component and which CPC citation applies. Revisit that map when pigments, alloys, recycled feedstock, finishes or suppliers change. This record addresses one chemical limit; it does not establish that the article meets phthalate restrictions, toy mechanical requirements, food-contact rules or every other chemical requirement relevant to its intended use.