CPSC clarifies dyed textiles require no lead testing

On 14 October 2015, U.S. Consumer Product Safety Commission ("CPSC") published a final rule that when component part testing can be used and which textile products have been determined not to exceed the allowable lead content limits on the Federal Register. The rule is effective on 14 December 2015 if CPSC receives no significant adverse comment before 13 November 2015.

The final rule amends 16CFR 1500.91 that dyed textile require no test for lead or total lead in coating no matter what dye technique is employed.

CPSC held that dyes and dyed textiles did not contain lead. So those products require no third-party testing. However, textiles after-treatment applications, including screen rints, transfers, decals, or other prints, need lead testing.

Amendments are also made to 16CFR 1109 (component part testing rules):
1. Section 1109.1(c) is revised to clarify subpart B to avoid misunderstanding.
2. Section 1109.5(a) is revised to clarify that the requirements of subpart B and C are only required if applicable in the circumstances identified in subparts B and C.
3. The amendment revises section 1109.11 (lead test in coating of toys) to update the reference from ASTM F963–08 to ASTM F963–11.
4. The amendment adds a reference to the 1109.13 (applicability for toy and child care article testing for their parts and finished products) concerning inaccessible component parts (16 CFR part 1199). This change will make the provision concerning phthalates (section 1109.13) consistent with the provision concerning lead.

Reminder: Dyed textiles require no lead testing when exported to the United States and related companies should notice that to avoid unnecessary tests. In addition, products intended to be placed on the U.S. market should follow component parts testing rules to avoid failure caused by unapproved reports.