The U.S. Consumer Product Safety Commission (CPSC) has released two documents which provide interpretive guidance and rules pertaining to its enforcement policies concerning tracking labels and inaccessible component parts. With the one-year anniversary of enactment of the Consumer Product Safety Improvement Act of 2008 (CPSIA) fast approaching (August 14, 2009), compliance with various requirements of the CPSIA will soon be mandatory.

The CPSC's statement of policy regarding interpretation and enforcement of the tracking labels requirement, issued July 20, 2009, outlines the background and purposes of the requirement and clarifies questions pertaining to format, content and individual types of products. Children's products manufactured on or after August 14, 2009, are expected to comply with the tracking labels requirement.

The CPSC's final interpretive rule regarding inaccessibility of components in children's products containing lead, issued July 23, 2009, provides clear guidance with respect to which product components or classes of components will be considered inaccessible under CPSIA. On August 14, 2009, children's products must comply with the 300 ppm limit for total lead content (reduced from 600 ppm), regardless of date of manufacture.

Read more about these two new CPSC policy documents.

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