Industry News
Updated Schedule of Enforcement for Products Requiring General Conformity & Third Party Testing Certificates under the CPSIA
TweetJanuary 24, 2010
Significant additions to the list of products for which the Consumer Product Safety Commission (CPSC) requires General Conformity Certificates (GCC) and third-party testing conformity certificates are set to take effect on February 10, 2010. The CPSC already requires third-party conformity certificates for the lead in paint ban, crib and pacifier standards, small parts ban, and lead content of metal components in children’s jewelry.
These requirements, which were scheduled to take effect on
Rule, Standard or Ban |
Non-Children’s Product General Conformity Certificate Requirement |
Children’s Product Conformity Certificate Based on Third-Party Testing |
Lead Paint on Children’s Products (16 CFR 1303) |
N/A |
Yes. Certification to 90ppm limit required for products manufactured after Aug. 14, 2009. |
Full-size Cribs (16 CFR 1508), Non Full-size Cribs (16 CFR 1509) and Pacifiers (16 CFR 1511) |
N/A |
Required for products manufactured after Jan. 20, 20009 |
Small Parts (16 CFR 1501 |
N/A |
Required for products manufactured after March 23, 2010 |
Lead in Metal Components of Children’s Metal Jewelry (CPSIA § 101) |
N/A |
Required for products manufactured after March 23, 2009. |
Bicycle Helmets (16 CFR 1203) |
GCC required for products manufactured after Feb. 10, 2010 |
Required for products manufactured after Feb. 10, 2010. |
Rattles (16 CFR 1510, 1500.18(a)(15) & 1500.86(a)(1)) |
N/A |
Required for products manufactured after Feb. 10, 2010. |
Dive Sticks (16 CFR 1500.18(a)(9) & 1500.86(a)(7) & (a)(8)) |
N/A |
Required for products manufactured after Feb. 10, 2010. |
Bunk Beds (16 CFR 1213 & 1513) |
GCC required for products manufactured after Feb. 10, 2010. |
Required for products manufactured after Feb. 10, 2010. |
Bicycles (16 CFR 1512) |
Required for products manufactured after May 17, 2010. |
Required for products manufactured after May 17, 2010. |
Lead Content in Metal Children’s Products & in Non-Metal Children’s Products |
N/A |
Required for products manufactured after Feb. 10, 2011. |
Ban on Lead-In-Paint in Paint & on Furniture (16 CFR 1303) |
N/A |
N/A |
Requirements for Child Resistance on Portable Gas Containers |
Required for products manufactured after Feb. 10, 2010. |
N/A |
Regulations for Special Packaging Required under the Poison Prevention Packaging Act (16 CFR 1700) |
Required for products manufactured after Feb. 10, 2010. |
N/A |
Ban on Extremely Flammable Contact Adhesives (16 CFR 1302) |
Required for products manufactured after Feb. 10, 2010. |
N/A |
Ban of Unstable Refuse Bins (16 CFR 1302) |
Required for products manufactured after Feb. 10, 2010. |
N/A |
Standard Refrigerator Door Latches (16 CFR 1750) |
Required for products manufactured after Feb. 10, 2010. |
N/A |
Carpets & Rugs (16 CFR 1630 & 1631) |
Stayed |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Caps & Toy Guns (16 CFR 1500.18(a)(5)) |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Phthalates |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Toy Safety Standard ASTM F964 |
Stayed |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Baby Walkers |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
|
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Children’s Sleepwear (16 CFR 1615 & 1616) |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Electronically Operated Toys (16 CFR 1500.18(b) & 1505) |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Durable Infant Products |
N/A |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
ATV;s |
Full GCC required for products manufactured after Feb. 10. 2010. |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Mattresses (16 CFR 1632 & 1633) |
GCC required for products manufactured after Feb. 10, 2010. |
Stayed, until 90 days after the Commission publishes requirements for accreditation of laboratories for testing. |
Matchbooks (16 CFR 1202), CB Antennas (16 CFR 1204), Lawnmowers (16 CFR 1205), Swimming Pool Slides (16 CFR 1207), Candles with Metal Wicks (16 CFR 1500.12(a)(2), Cellulose Insulation (16 CFR 1209), Garage Door Openers (16 CFR 1211), Cigarette Lighters (16 CFR 1210), Multi-Purpose Lighters (16 CFR 1212), Fireworks (16 CFR 1500.14(b)(7) |
GCC required for products manufactured after Feb. 10, 2010. |
N/A |
For the lead content testing requirements described above, the CPSC has voted to adopt an interim enforcement policy allowing component part lead testing for children’s products. This enforcement policy allows importers and domestic manufacturers to certify their products by sending samples of the entire children’s product out for independent testing or having testing performed on the paints for compliance with the 90 ppm lead in paint limit or on a particular accessible component for compliance with the 300 ppm lead limit.
For more information on any of the certification requirements described above, please contact a Barnes/Richardson attorney.