NAPIM

Consumer Product Safety Improvement Act of 2008 – Summary

On August 12, 2011, the Consumer Product Safety Improvement Act of 2008 (CPSIA) was signed into law. It was designed to address longstanding complaints about some aspects of the CPSIA.1 This action came two days before the CPSIA would have made all existing children’s products containing more than 100 ppm of lead illegal to sell or resell, even if they were in compliance with all applicable consumer product safety standards at the time of manufacture. This client alert reviews the key provisions of these just-in-time amendments, Public Law 112-28.

Ink Manufacturers Impact/FAQ

Key Points:

  • Ordinary books, even those intended for readers of all ages are not covered by the CPSIA
  • Printing inks used in printing children’s books are not subject to any of the CPSC regulations because they are not classified as consumer products
  • In late December of 2009 (Federal Register December 28th, 2009), the CPSC extended its stay of enforcement of the CPSIA 2008 third-party testing and certification for lead content in children’s products until February 10, 2011. Specifically, only children’s products manufactured after this date will be subject to third-party testing and certification requirements.
  • The test method specified by the CPSC (CPSC CH-E1002-08) for total lead content determination in children’s products is designed for use with articles and cannot be used for printing inks

CPSIA 2008 Resources

CPSIA 2008 Decision Tree