Age Grading and Products with Small Parts

Introduction

Age grading practices are important to ensure products are appropriate and safe at particular stages of child development.  The product or toy must be safe for the intended user, a primary consideration should be potential choking or asphyxiation hazards associated with small parts.

Correct age grading is important to ensure the correct protocols for product testing.  As mentioned above, while lead content testing is required for all items, the acceptable limits are much stricter for items manufactured for children.  Also, there are additional tests for safety such as small parts and mechanical hazards.

Age Grade Key Concepts

Consumer Product

Any article produced or distributed (i) for sale to a consumer for use in or around a resident, school, in recreation, or otherwise, or (ii) for the personal use, consumption, or enjoyment of a consumer (General Use)

Children’s Product

A product designed or intended primarily for use by children 12 years of age or younger

Children’s Toy

A children’s product designed or intended by the manufacturer for use by a child in play (ASTM F963 goes up to 14 years of age

Children’s Product Certificate (CPC)

Before a toy designed for a child aged 14 or younger can be sold in the U.S., the company either producing the toy in America or importing it into the country must test their product by a CPSC (Consumer Product Safety Commission)-accepted laboratory.  Once the product is determined compliant, a Children’s Product Certificate (CPC) should be presented with each batch of product to the retailer and, when requested, to the CPSC.

A CPC includes the following information:

• A detailed product description covered by the CPC
• Every CPSC product safety rule required for certification
• Manufacturer or importer information
• Contact information for the individual maintaining records of test results
• Product origin
• Any third-party, CPSC-accepted laboratory information used in the certification process

See http://www.cpsc.gov/cpc

Small Parts

A “small part”, is defined as any toy part (or any broken piece) which fits completely in a cylinder with a slanted depth, from 1” to 2.25”, and a diameter of 1.25”. These dimensions are meant to approximate a fully extended throat of a child under three.

Relevant Regulatory Review

CPSC/CPSIA

• Consumer Product Safety Commission/Consumer Product Safety Improvement Act.  See CPSIA for additional details.
• Advantus items covered:
  • Children’s products (any product designed for use by a child 12 and younger).  See children’s products and age determination guidelines.
• Requirements:
  • Third-party testing and certification are required for those toys designed or intended primarily for children 12 and under.  Renewed annually.
  • CPC: All toys designed or intended primarily for children 12 years of age and younger must be third-party tested and be certified with the issuance of a Children’s Product Certificate (CPC).
  • The tracking label must be permanently attached to product.
  • Total lead content
    • Less than 100 parts per million (ppm) of total lead content inaccessible parts.
  • Lead in paint/coatings
    • Less than 90 parts per million (ppm) in paint or any similar surface coatings.
  • Phthalates
    • Less than 100 parts per million (ppm) DEHP, DBP, BBP, DINP, DIDP, DnOP (computed for each phthalate, individually) in children’s toys and certain child care articles.

Plastic Bag Warning Label Requirements

Several states and cities have laws that require suffocation warning labels for plastic bags.

In addition to regulations on the wording of warnings printed on the bags, there are specific regulations that relate to size requirements, material, repeat printing at different intervals, clarity of the font printed, and more.

Each state/local entity also has its own violation penalties if a bag is found non-compliant with these laws.