CPSC Issues Guidelines for Inaccessible Component Parts

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February 14, 2013

In a February 14, 2013, Federal Register notice, the Consumer Product Safety Commission (CPSC) outlined guidance on inaccessible component parts in children’s toys subject to section 108 of the Consumer Product Safety Improvement Act of 2008 (CPSIA).  Section 108 of the CPSIA prohibits the sale of “children’s toys or child care articles” that contain more than 0.1% of three specific phthalates (phthalate , dibutyl phtlate, and benzyl butyl phthalate).  The Act contains an exception for phthalate containing component parts that the Commission deems inaccessible to children.   

The notice detailed which types of components are considered “not accessible”, including parts covered by a casing or sealed covering and parts that pass the Commission’s “use and abuse” tests.  Additionally, the notice stated that vinyl covered mattress and sleep structures are considered accessible, even if covered by fabric.

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