NEWS

Washington State published CSPA Reporting Rule guidance documents

On 6 September, 2011, Washington State published key guidance documents for the implementation of Children’s Safe Products Act (CSPA) Reporting Rule. The rule requires manufacturers of children’s products to report if their products contain certain chemicals that are considered by WA State to be Chemicals of High Concern for Children (CHCC).

The Children’s Safe Products Act (CSPA) passed by the state of Washington in 2008 established a reporting rule for 66 chemicals if one or more of those chemicals are contained in certain children’s products. The reporting rule is triggered if a CHCC is present as a contaminant at a concentration of more than 100 ppm or as an intentionally added CHCC if the CHCC exceeds the Practical Quantification Limit (PQL).

The rule applies to children’s products like:
• Toys, Children's cosmetics, Children's jewelry and Child car seats or
• A product designed or intended by the manufacturer to help a child with sucking or teething, to facilitate sleep, relaxation, or the feeding of a child, or to be worn as clothing by children.

The guidance documents clarify following aspects of the reporting rule:
• Who has the burden of responsibility,
• Which product categories subject to the reporting rule,
• Product component level,
• Due diligence by manufacturers,
• Practical quantification limits (PQLs).

The largest manufacturers that make those products that are intended to be placed in a child’s mouth or on their skin, or products for children age 3 and under, must report first. Starting August 2012, the largest manufacturers must report to Ecology if any of these listed chemicals are intentionally added to, or occur as contaminants in,children’s products that are sold in Washington State. Smaller manufacturers havemore time, depending upon their size. Retailers who only sell, but do not make or import, children’s products are not subject to this reporting requirement. Highlights of the annual notice due dates are summarized in Table 1.

There are differences between CHCC and SVHC. If you want to know further information, please refer the following links:
The Reporting List of Chemicals of High Concern to Children (CHCC) can refer:
http://www.ecy.wa.gov/programs/swfa/cspa/chcc.html
The Candidate List of SVHC can refer:
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

Leo-MTS will follow up and inform interested parties as developments on US and other international legislation occur. Please do not hesitate to contact us for further information.

More information, please refer:
http://www.ecy.wa.gov/programs/swfa/cspa/