CPSC Issues Final Definition of Children’s Products

December 2, 2010 at 11:23 pm Leave a comment

Steve Kahane, President of International Coatings

This week, we asked International Coatings’ president, Steve Kahane, to briefly summarize the recent CPSC final definition of what is considered a children’s product.  There seems to still be a lot of confusion out there, so here is Steve’s summary:

“The Consumer Product Safety Commission (CPSC) just put into effect its long awaited interpretative rule that provides guidance on whether a product is considered a ‘children’s’ product.  This guidance is critical to determining whether a product must meet the compliance, testing, labeling and reporting requirements for toys and child care articles under the Consumer Product Safety Improvement Act (CPSIA).

The Commission determined that a children’s product is one that is designed or intended primarily for use by children 12 years of age or younger.  It is these products that must comply with the CPSIA. 

Alternatively, the Commission stated that products determined to be ‘general use’ products are not subject to the CPSIA.  These are products not designed or intended primarily for the use by children 12 years of age or younger.  General use products include, however, products that children may interact with, but are designed for use by individuals over 12 years of age.  Examples would include candles and fireworks.

The following four factors are to be considered in determining whether a product is intended primarily for children 12 years of age or younger.  These factors are to be considered together as a whole in making the determination. 

  1. Manufacturer’s statement about the intended use of the product, including a label on the product.
  2. Representation of the product in its packaging, display, promotion or advertising as appropriate for use by children.
  3. Whether the product is commonly recognized as being intended for use by children 12 years of age or younger.
  4. Age Determination Guidelines issued by the Commission (in September 2002) that consider the appeal of a product to different age groups as well as capabilities of these age groups to use the products.


You can learn more on the interpretative rule at the CPSA web site, http://www.cpsc.gov/about/cpsia/childproducts.html.

You can also learn more about the CPSIA and the interpretative rule by visiting the Specialty Graphic Imaging Association (SGIA) web site, http://www.sgia.org/technology/CPSIA/index.cfm.

You can sign up for CPSC email updates on the CPSIA at https://www.cpsc.gov/about/cpsia/cpsialist.aspx.”

Read Steve’s earlier blog for more on the CPSIA Phthalate and Lead regulations:
For more on Phthalates, please also visit Ed Branigan’s blog:  Phthalates And Why It’s Impacting Textile Screen Printing
For more on Phthalates, please go to our website at www.iccink.com, and visit our Phthalates page.

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