Other Requirements

Section 103. Tracking Labels for Children's Products

The CPSIA has some other safety regulations that affect infant and toddler products. The act stipulates that "durable infant and toddler products," such as cribs, strollers, and stationary entertainers, can use product registration cards in case of recall. The CPSC requires a review of the voluntary safety standards for these products and may make them more stringent federal regulations. The CPSIA places a strong emphasis on crib safety. It is illegal not only to manufacture or sell cribs that do not meet federal safety standards but also to provide them for use, such as in hotels or day - care centers.

The CPSIA also has requirements for how manufacturers, distributors, and retailers advertise products that may contain small parts and pose a choking hazard. The law stipulates a searchable online database for recalls, safety information, and accident reports of products that cause harm.

Section 103(a) of the new act requires manufacturers to print tracking labels or other obvious permanent identification marks on consumer products intended for children 12 years old or younger. The tracking labels must contain certain basic information, including the product source, the product manufacturing date, and more details about the product manufacturing process (such as batch numbers or serial numbers). The scope of this clause is quite extensive, covering all children's products, including, but not limited to, clothing, shoes, and not just toys and other regulated products. Congress modified the requirements for tracking labels, using the phrase "to the extent feasible," acknowledging that it may not be feasible to require small toys and other small products that are not individually packaged during manufacturing and shipping to have obvious permanent identification marks.

The US Consumer Product Safety Commission is authorized to announce rules to explain in detail the relevant requirements for tracking labels. Moreover, the commission may require that more information printed on children's product tracking labels be extended to tracking labels for other consumer products in the future.

Section 103(c) of the new act also involves various claims by manufacturers stating compliance with mandatory or voluntary safety rules. Since October 12, 2008, no product packaging, advertisement, or label can print a certain safety standard unless the product actually complies with that standard.

Effective Dates: The requirements for tracking standards come into effect one year after the implementation of the act on August 14, 2009. The requirements for prohibiting self - claiming statements for advertising purposes come into effect 60 days after the implementation of the act, or since October 13, 2008.

Section 104. Standards for Durable Infant and Toddler Products and Consumer Registration

The act's Section 104 requires the US Consumer Product Safety Commission to study and develop safety standards for infant and toddler products. Congress specified that the products the commission must study include: full - size cribs and non - full - size cribs; toddler beds; high chairs, booster seats for toddlers, hook - on seats; bath stools; safety gates or fences for protecting children; play yards; stationary activity centers for children; baby carriers; strollers; toddler walkers; swings; infant carriers, and bassinets. The commission must either convert the current voluntary standards into mandatory standards or develop more stringent safety standards. The commission can decide which types of products to prioritize in rule - making, but it must develop two regulations by August 14, 2009, at the latest, and announce two regulations every six months until all products have mandatory standards. Once the commission announces these safety standards, it is illegal to manufacture, sell, or import products that violate the new safety standards, and civil or criminal liability will be pursued.

Congress specified that the mandatory standards for cribs apply not only to cribs, portable cribs, and play yards sold on the market or wholesaled through other commercial channels but also to those used or rented in hotels, child - care centers, home - based child - care settings, or other locations.

This section of the act also requires the commission to announce a final regulation on August 14, 2009, requiring manufacturers of the above - mentioned infant and toddler products to provide consumers with a prepaid registration card so that manufacturers and retailers can contact customers if the product is recalled or other safety information needs to be provided.

Finally, this section of the act requires the Consumer Product Safety Commission to regularly review the methods of issuing product recall notices two years after the promulgation of the mandatory product registration form regulations to confirm that these methods can effectively promote product recalls. Within three years after the entry into force of the act (August 14, 2011), the commission must submit a report on the evaluation of product recall methods to Congress. If the commission determines through regulations that a certain method is as effective as or more effective than the registration form required by regulations in promoting product recalls, the commission must submit a report to Congress and allow manufacturers to use that method instead of the registration form required by regulations.

Section 215. Inspection of Private Laboratories; Confirmation of the Supply Chain

The new act clarifies that the US Consumer Product Safety Commission has the right to inspect private laboratories that test products to support the certification of children's products manufactured by manufacturers. The new act expands the scope of inspection and record - keeping for importers, retailers, and wholesalers of consumer products, requiring them to confirm the names and addresses of product manufacturers. The act requires manufacturers to keep records of each retailer or wholesaler dealing with consumer products and contractors involved in the product manufacturing process.

Effective Date: This section came into effect on the implementation date of the new act, that is, August 14, 2008.

This document is an informal description of the provisions in the Consumer Product Safety Improvement Act. The document does not replace or substitute the requirements specified in the new act. The listed dates are based on the enactment date of the act. Some parts may change depending on the final decisions of the commission.

Technical Requirements and Developments of the CPSIA for Products
Requirements for Children's Products Containing Lead or Lead - Based Paints:
Phase - out restrictions are imposed on the lead content of all components of children's products. It is required that within a three - year period, the limit of the total lead content of any accessible part of the product is ultimately reduced from not exceeding 600 ppm (0.06%) by weight to not exceeding 100 ppm (0.01%) by weight.

Lead content limit (total lead content as a percentage of weight)

In children's products, excluding non-accessible components

Not exceeding 600ppm (0.06%), 180 days after the date of promulgation of the regulation (February 10, 2009)

Not exceeding 300ppm (0.03%), 1 year after the date of promulgation of the regulation (August 14, 2009)

Not exceeding 100ppm (0.01%), 3 years after the date of promulgation of the regulation (August 14, 2011)

Lead paint on children's products and toys

Not exceeding 90ppm (0 .009%), 1 year after the date of promulgation of the regulation (August 14, 2009)

Mandatory third-party testing requirements for certain children's products:

90 days after the regulation takes effect (November 12, 2008), manufacturers and private labelers of children's products must

---Send the products to a qualified independent third-party testing agency for relevant testing

---Issue a certificate to prove that the product complies with applicable standards or regulations

---For specific mandatory product information, testing agency requirements and time requirements, please pay attention to the relevant technical document updates of EBO