CPSC(CONSUMER PRODUCT SAFETY COMMISSION) & Children’s Product Safety Rules
Children’s products are subject to a set of International federal safety rules, called children’s product safety rules. Determining how the product is classified enables to identify correctly the set of children’s product safety rules applicable to your product. The law defines a “children’s product” as a consumer product designed or intended primarily for children 12 years of age or younger.
The Consumer Product Safety Improvement Act provides for specific lead limits in children’s products. Section 101(a) of the CPSIA states that products designed or intended primarily for children 12 and younger may not contain more than 100 ppm of lead. Paint, coatings or electroplating may not be considered a barrier that would make the lead content of a product inaccessible to a child. Materials used in products intended primarily for children 12 and younger that are treated or coated with paint or similar surface-coating materials that are subject to 16 CFR part 1303, must comply with the requirements for lead paint under section 14(a) of the Consumer Product Safety Act (CPSA), as amended by section 102(a) of the CPSIA.
Lead in Paint and Similar Surface Coatings
All children’s products, and some furniture, for adults and children, must not contain a concentration of lead greater than 0.009 percent (90 parts per million) in paint or any similar surface coatings. Household paint must also meet this requirement. Paint or any similar surface coatings for consumer use exceeding 0.009 percent by weight of the total nonvolatile content of the paint (90 parts per million) and products specified in 16 CFR §1303.1 that bear such paint or coatings are banned hazardous products.
Total Lead Content
With a few limited exceptions explained below, all children’s products must not contain more than 100 parts per million (ppm) of total lead content in accessible parts. Please see our webpage on total lead content for more in-depth information on this requirement.
Testing Exemptions: The Commission has determined that certain materials do not need to be tested by a third party laboratory. To rely on the following list, the materials must be untreated and unadulterated, and the product must be made exclusively of the following materials:
- certain natural and synthetic textiles, such as cottons, wools, and polyesters, among others;
- pure wood (not plywood or other composites);
- paper and other similar products made from cellulosic fiber;
- CMYK ink printing processes;
- certain plant-derived and animal-derived materials, such as animal glue, bee’s wax, seeds, nut shells, flowers, sea shells, leather;
- certain precious, semi-precious gemstones and pearls; and
- certain stainless steel and precious metals, as listed.
All clothing (Children Safe T-Shirts) must comply with the Standard for the Flammability of Clothing Textiles, 16 CFR part 1610. Manufacturers and importers must certify clothing as compliant in a General Certificate of Conformity (GCC) (for adult or general-use apparel) or in a Children’s Product Certificate (CPC) (for children’s apparel primarily intended for children 12 and under).
Many commonly available textiles used in wearing apparel do not require flammability testing to show compliance with the flammability standard based on their fabric weight or fiber content 16 CFR §1610.1(d):
- Plain-surface textile fabrics, regardless of fiber content, weighing 2.6 ounces per square yard (88.2 grams per square meter) or more.
- All fabrics, both plain surface and raised-fiber surface, regardless of weight, made entirely from any of the following fibers or entirely from the combination of the following fibers: acrylic, modaacrylic, nylon, olefin, polyester, and wool.
If you are relying on this testing exemption, Section 6 of your Certificate will need to reference 16 CFR §1610.1(d) and specify the portion of the exemption on which you are relying (e.g., 100% polyester.)
OEKO-TEX CERTIFIED BABY SAFE INKS
Seiko Epson Corporation (TSE: 6724, “Epson”) became the first company in Japan*1 to receive the Zurich-based International Oeko-Tex Association’s Eco Passport certification for sustainable textile chemicals. Certification was obtained through the Nissenken Quality Evaluation Center (“Nissenken”), the only certification institute in Japan for Eco Passport. Certified products include the UltraChrome DS ink for the SC-F60, SC-F62, SC-F70, SC-F71, SC-F72, and SC-F92 series’ of SureColor dye-sublimation transfer printers, as well as for UltraChrome DG ink and auxiliary fabric preparation products for the SureColor SC-F2000/SCF2100 garment printer.
In Japan, the Eco Passport certification system was launched by Nissenken in June 2016. Following on the heels of the Oeko-Tex Standard 100, a worldwide safety certification system in which textile products are tested for harmful substances, Eco Passport is a new testing and certification mechanism that textile chemical manufacturers and suppliers can use to demonstrate that their colorants, auxiliaries, finishing assistants, and other textile chemicals can be used in safe and sustainable textile production. The Eco Passport initiative seeks to confirm compliance with restrictions enacted in April 2016 on the use of certain arylamines*2 and to ensure the safety and sustainability of chemicals, colorants, and auxiliaries upstream in the textile industry supply chain.
Epson, which offers a range of inkjet printers equipped with the company’s powerful Micro Piezo technology, is promoting the digitalization of textile and garment printing. The company’s dye-sublimation transfer printers, garment printers, and digital inkjet textile printers enable faithful color reproduction on textiles, which is difficult to achieve with analog printing processes. They also render complicated designs down to the finest details while shortening the printing process.
To enable it to provide the same high level of product quality in any country and region in the world, Epson has established unified quality assurance and product safety management policies. Epson’s product safety and environmental compliance requirements are set forth in the Epson Quality Standard (EQS). This comprehensive set of unified standards is implemented across the Epson Group. EQS specifies independent controls that the company widely implements to meet or exceed legal and regulatory requirements in each country.
Epson applied to Nissenken for Eco Passport certification to reassure its customers that its textile products meet international safety standards.
Going forward, Epson will seek to contribute to the development of a sustainable society by providing customer value in the form of reduced environmental impacts across the life cycles of its products and services.
*1 According to Nissenken research as of October 31, 2016
*2 In 1992, the Oeko-Tex Standard 100 for harmful substances in textile products banned the use of certain arylamines that produce carcinogens when they decompose. The use of certain arylamines was legally restricted in Germany in 1994, and thereafter in the E.U., and more recently in China and South Korea. In April 2016, Japan enforced the Act on Control of Household Products Containing Harmful Substances, adding restrictions on the use of certain arylamines.
Oeko-Tex is the world’s leading testing and certification system for verifying the safety of textile products.
Oeko-Tex certifications for textile products cover all stages of production, from raw materials to end products. There is also a certification for environmentally friendly production sites. The Oeko-Tex Standard 100 is a certification system for products. In the more than two decades since its inception, more than 150,000 articles have been tested globally. This certification, which is only granted for articles that clear strict criteria for more than 300 harmful substances, also meets international restrictions on harmful substances, including Japan’s azo restrictions in textile products. Eco Passport was established as a safety certification system that is applicable further up the supply chain than the Oeko-Tex Standard 100.
We at Print My Fashion only use Oeko-Tex Certified Epson DS and DG Inks which are Safe for kids including Babies.
