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

Vol. 849 | 18 Aug 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

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).