U.S. – Deadline Approaching for the Washington State Children’s Safe Products Act Reporting Rule

Vol. 849 | August 18, 2015

The state of Washington, as part of the Children’s Safe Products Act (CSPA) Reporting Rule, requires reporting for the 66 chemicals that are designated as chemicals of high concern (CHCC), for an accessible component(s) of certain children’s products (for ages under 12 years). Reporting is required under following conditions:

  • CHCC(s) is intentionally added and present above practical quantitation limit (PQL), or
  • CHCC(s) present as contaminant above 100 parts per million (ppm)
  • Manufacturing control program exemption can be sought for contaminant(s) present at a level above 100 ppm

The reporting deadlines have been phased-in, starting in August 2012, based on the size of the manufacturer and the Tier of the product, as set out in the table below.

August 31, 2015, is the next phased-in reporting deadline for the Washington CSPA Reporting Rule. It is the first time reporting will be required by the Smaller manufacturers making Tier 1 products, the Small manufacturers making Tier 2 products, and the Medium manufacturers making Tier 3 products.

In addition, annual reporting will also be required by the Largest manufacturers making Tier 1 and Tier 3 product(s); the Larger manufacturers making Tier 2 and Tier 3 product(s) and the Medium manufacturers making Tier 1 and Tier 2 product(s).

The reporting data has to be entered in online portal hosted by the State of Washington Department of Ecology at http://www.ecy.wa.gov/programs/swfa/cspa/reporting.html

Manufacturer Category (annual aggregate gross sales ($) in USD, within and outside State of Washington, based on the manufacturer's most recent tax year filing).

Tier 1 [Products intended to be put into a child's mouth (e.g., children's products used for feeding, sucking, some toys) or applied to the child's body (e.g., children's products used as lotions, shampoos, creams), or any mouthable children's product intended for children under three year.]

Tier 2[Products intended to be in prolonged (more than one hour) direct contact with a child's skin (e.g., clothes, jewelry, bedding)]

Tier 3[Products intended for short (less than one hour) periods of direct contact with child's skin (e.g., many toys)]

Tier 4 [Product components that during reasonably foreseeable use and abuse of the product would not come into direct contact with the child's skin or mouth (e.g., inaccessible internal components for all children's products)]

Largest
($ > 1 billion)

August 2012

February 2013

August 2013

case-by-case

Larger
(250 million < $ ≤ 1 billion)

February 2013

August 2013

August 2014

case-by-case

Medium
(100 million < $ ≤ 250 million)

August 2013

August 2014

August 2015

case-by-case

Small
(5 million < $ ≤ 100 million)

August 2014

August 2015

August 2016

case-by-case

Smaller
(100,000 < $ ≤ 5 million)

August 2015

August 2016

August 2017

case-by-case

Tiny
($ < 100,000)

August 2016

August 2017

August 2018

case-by-case

 

For questions, please contact Laxmi Ravikumar (laxmi.ravikumar@intertek.com, 630-209-9265) or Pratik Ichhaporia (pratik.ichhaporia@intertek.com, 312-906-7720).

 

Related topics: 2015 | 2015 | Toys and Childrens Products | Toys and Childrens Products