Specified Phthalates in Children’s Toys and Child Care Articles

A children’s toy is designed or intended for a child aged 12 or younger for play; a child care article is designed or intended to facilitate sleep, feeding, sucking or teething for a child aged three or younger. Apply the definitions in part 1307 to the actual article. The assessment then focuses on accessible plasticized components rather than all components indiscriminately.

The regulation restricts DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP and DCHP above 0.1 percent, or 1,000 ppm, for each regulated phthalate in the relevant component. A statement about the total amount of all plasticizers is not equivalent to results for these substances. Identify the analytes and reporting limits rather than accept a generic “phthalate free” conclusion.

Part 1199 addresses whether components are inaccessible for phthalate purposes. Examine the finished design and reasonably foreseeable use and abuse. Obtain material information for soft plastics, coatings and other potentially plasticized components. Polymer identity alone may not describe the plasticizer system, added colorants or a supplier’s later formulation change that alters the chemical composition of the component.

Children’s products subject to the restriction generally require accepted third-party laboratory evidence and CPC certification, with applicable exceptions and material determinations considered. CPSC identifies an approved phthalates test method in its guidance. Reports should connect the tested component, sample preparation, individual analytes and measured concentrations to the product model and production material represented by the test.

Some CPSC determinations reduce testing burdens for specified materials when their conditions are met. Preserve the composition information and basis for relying on a determination. A material that has been plasticized, treated or reformulated may not fit an earlier assumption. Component-part testing under part 1109 also requires traceability and due care; it is not a reason to accept unrelated supplier paperwork.

Use a component map to assign phthalate evidence, lead-content evidence and coating evidence separately. A passing phthalates report does not establish compliance with toy mechanical requirements, tracking labels or other chemical legislation. When reviewing a new supplier or design revision, check the actual material and test coverage before carrying the previous CPC and reports forward to a different finished article.