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The product recalls by Mattel and several other
US toy companies in mid 2007 have no doubt made big impact on every aspect of the toy
industry worldwide. Since then, countries around the world have tightened their
product safety acts, including following new regulations of the United States:
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US Consumer Product Safety Improvement Act (CPSIA) requires a Certificate of
Compliance (COC) accompanying goods entering into the US as of November
12th, 2008. Check http://www.cpsc.gov/about/cpsia/102rfc.pdf
for details.
* A sample of COC draft can be viewed
here.
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Under the CPSIA regulation, product targeting to children 12 years old
and under is required to be tested by third party certified by US Consumer
Product Safety Commission ("CPSC"). The
new laws became effect as of February 10th, 2009; referred to http://www.cpsc.gov/ABOUT/Cpsia/cpsia.HTML
for details.
* A summary
of international principal toy safety requirements can be viewed here (http://www.intertek-labtest.com/brochures/ToyGiftPremiumTesting?lang=en)
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It's important to note that age cutoffs under the CPSIA regulation are
determined by following guidelines (http://www.cpsc.gov/ABOUT/Cpsia/faq/children.html):
- A statement by the manufacturer about the intended use of the product,
including a label on the product if such statement is reasonable.
- Whether the product is represented in its packaging, display, promotion or
advertising as appropriate for use by children 12 years of age or younger.
- Whether the product is commonly recognized by consumers as being intended
for use by a child 12 years of age or younger.
- The Age Determination Guidelines issued by the Commission staff in
September 2002, and any successor to such guidelines.
4. US Customs and Border Protection Rule 10+2 Initiative
goes into effect January 26th, 2009. Referred to http://www.cpsc.gov/ABOUT/Cpsia/faq/children.html
for details.
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CHL Products Statement
Like most of manufacturers, we purchase
production paints from
paint suppliers. This means we are basically relying on suppliers to provide
quality paints. While over the years, we have stuck to a rule of using best materials
in our production, including paints, which usually means higher cost but
generally safer in use, nonetheless, we cannot guarantee the materials we use
are 100% compliant with the international safety standards without further
testing.
From time to time, especially since the Mattel recall event,
we have had some paint sample tested by a testing lab; note the paint sample is a
mix of various paints and colors we normally use. Here is copy of a
test
report by Intertek (www.intertek-labtest.com),
a lab test firm certified by CPSC. This test confirmed that
our paints passed the US ASTM F963 safety standard.
We have to emphasize, nonetheless, these are just general
tests, meaning they are not tested based on any particular product, so cannot
be used as a proof for compliance. While we will do our best to ensure product safety,
we can't afford to have every order of products tested, for two reasons. First,
testing cost could be substantial given the relative low quantity in custom
order; second, product safety is not just about paints, but also about design,
application, and Government regulations, so is out of our control. To be certain, therefore, we recommend that clients who have
safety
concern do a special test for their products, especially those targeting to
children. Further arrangement can be discussed on project basis.
We want to further emphasize, as we are not expert in
government regulations and compliance, we assume no responsibility for any
losses or liability whatsoever incurred by any person, resulting from or
attributable to the use of the information on this site. You should consult
with government agents, certified testing firms, or specialized law firms for
legal advice.
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Some product design implications
- In design of collectible toys or figures, avoid elements that would
possibly be recognized as children toys
- For collectible toys or figures not intended for children, make sure to
label them so, including correct representation in display, marketing, and
selling activities
- Test cost can be substantial, especially in low quantity production; so
children toy production should have some level of volume so as to control
the unit cost
- As test cost is determined by colors, among other factors, reducing number
of colors would help reducing testing costs
- At this point, we don't accept production for toys targeting to children 5
years old and under
Resources
Client should consult with experts for advice, while government agencies
and certified test firms can be the good sources. Following are some useful
links:
*
CPSIA general web-site -http://www.cpsc.gov/about/cpsia/cpsia.html
*
CPSIA link to listing of product
covered under Act - http://www.cpsc.gov/cgi-bin/regs.aspx
*
CPSIA link to product not
subject to Act - http://www.cpsc.gov/businfo/regsbyproduct.html
*
CPSIA Link to listing of accredited
Labs - http://www.cpsc.gov/about/cpsia/accredited.html
*
Import Safety Web-site - http://www.importsafety.gov/
*
Web-site link to Global Alphabetical
Country List of Internal Lab. Accreditation Cooperative
Members - http://www.cpsc.gov/businfo/regsbyproduct.html
*
Link to ST&R law firm providing
specialized CPSIA compliance programs and webinars – WorldTrade\INTERACTIVE
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