SPARKLE Volume 478 / 22 January 2010

Interim Enforcement Policy on CPSIA

CPSC has recently announced an interim enforcement policy regarding component testing and certification of children's products and other consumer products to the 90 parts per million (ppm) lead in paint limit and to the 300 ppm lead content limit for children's products established in section 101 of the CPSIA.

Certification to lead content limits for children's metal jewelry and other children's products based on component testing

The Commission will accept and intend to issue rules governing certification of a children's product as being in compliance with the 300 ppm lead content limit based on testing of individual components of a product. However, the manufacturer should ensure that:

1. The component sent to a third party test lab is representative sample of the components of that used on the final product;

2. The manufacturing process does not add lead from an untested source, such as the material hopper; regrind equipment, or other equipment used in the assembly of the finished product;

3. Each type of component for testing should be drawn randomly from the batch or lot of such components to be used in making the final product;

4. Certifiers (domestic manufacturers or importers) should be able to trace that component to its original component manufacturer.

Certification to lead paint limits based on testing of paint samples not obtained from the final product

The Commission will accept and intend to issue rules governing certification of a children's product as being in compliance with the 90 ppm lead paint limit based on testing of paints before they are applied to a product. However, the manufacturer should ensure that:

1. Each paint sample sent to a third-party test lab is representative of that used on the final product;

2. Certified paints are not later contaminated with lead from other sources before or during application to the product;

3. Certifiers (domestic manufactures or importers) should be able to trace that paint to its original paint manufacturer.

Asia Pacific - 2/F, Garment Centre, 576 Castle Peak Road, Kowloon, Hong Kong, Tel: +852 2173 8888 Fax: +852 2786 1903 North America - 2107 Swift Dr., Ste 200, Oak Brook, IL 60623, Tel: +1 630 481 3111 Fax: +1 630 481 3101

Latin America - 8300 N.W. 53rd Street, Suite 400, Miami, FL 33166, Tel: +1 305 513 3000 Fax: +1 305 513 2856 Europe, Africa, Middle East - ECOPARC 2, 27400, Heudebouville, France, Tel: +33 2 32 09 36 36 Fax: +33 2 32 09 36 59

Web: www.intertek.com/consumergoods E-mail: consumergoods@intertek.com Disclaimer Intertek made all reasonable efforts to ensure the accuracy of the information. However, the information provided should not be relied upon as legal advice or regarded as a substitute for legal advice. The reader should exercise his own care and judgment before relying on this information in any important matter. Copyright © 2010 Intertek Group. All Rights Reserved.

SPARKLE Volume 478 / 22 January 2010

Interim Enforcement Policy on CPSIA

The interim enforcement policy will take effect immediately and supersede the following documents:

1. "Statement of Commission Enforcement Policy on Section 101 Lead Limits" announced on February 6, 2009;

2. "Interim Enforcement Policy for Children's Metal Jewelry Containing Lead" issued on February 3, 2005.

Although this CPSC Interim Enforcement Policy allows certification based on component testing or wet paint testing, we recommend manufacturer should check the acceptance from the importer before applyingthis approach.

The Solution:

Intertek, an internationally accredited laboratory, offers a variety of solutions and services while lead content testing remains one of our fortes. We have earned the confidence of our clients with dedicated professionalism and accuracy in our testing services. Dedicated to Total Customer Focus, we are ready to offer any assistance in protecting our clients’ most important assets - brand and reputation.

Should you have any queries on the above news, please contact Ms. Yandy Pak at Tel: (852) 2173-8644 / Mr. Michael Chan at Tel: (852) 2173-8639 / Fax to: (852) 2785-8570 / Email: intertek.tfh.info@intertek.com.

Asia Pacific - 2/F, Garment Centre, 576 Castle Peak Road, Kowloon, Hong Kong, Tel: +852 2173 8888 Fax: +852 2786 1903 North America - 2107 Swift Dr., Ste 200, Oak Brook, IL 60623, Tel: +1 630 481 3111 Fax: +1 630 481 3101

Latin America - 8300 N.W. 53rd Street, Suite 400, Miami, FL 33166, Tel: +1 305 513 3000 Fax: +1 305 513 2856 Europe, Africa, Middle East - ECOPARC 2, 27400, Heudebouville, France, Tel: +33 2 32 09 36 36 Fax: +33 2 32 09 36 59

Web: www.intertek.com/consumergoods E-mail: consumergoods@intertek.com Disclaimer Intertek made all reasonable efforts to ensure the accuracy of the information. However, the information provided should not be relied upon as legal advice or regarded as a substitute for legal advice. The reader should exercise his own care and judgment before relying on this information in any important matter. Copyright © 2010 Intertek Group. All Rights Reserved.