CPSCNot often is it considered a victory when the status quo remains unchanged after a year of efforts, but a recent Consumer Product Safety Commission (CPSC) ruling found that inaccessible electronic components in children’s products will not be subject to the lead limits that were enacted last summer under the Consumer Product Safety Improvement Act (CPSIA). This finding is critical to the electronics industry because electronics manufacturers building children’s products will not need to meet CPSIA lead limits, which are lower than the limits in the European Union Restriction on Hazardous Substances Directive. Now that the dust has settled, the electronics industry remains virtually unaffected.

When the CPSIA was first enacted in August 2008, it was not clear whether parts contained in electronic products would be considered inaccessible or accessible and therefore subject to the CPSIA lead limits of children’s products. The law instituted a phased-in ban on lead in children’s products, requiring that lead levels be reduced to 600 parts per million (ppm) by weight in any part of a children’s product by Feb. 10, 2009; 300 ppm by Aug. 14, 2009; and 100 ppm by Aug. 14, 2011.

In multiple comments to the CPSC, IPC contended that if a lead-containing component part is not accessible to a child, it should not be subject to the lead limits under CPSIA. IPC, in conjunction with the Information Technology Industry Council (ITI) and the Consumer Electronics Association (CEA), pointed out that some lead containing electronic components are, by design, not accessible to children because the lead is fully enclosed within a component that is itself within the electronic device.

In the August 7, 2009 final ruling, CPSC agreed with IPC’s interpretation of an inaccessible component part. The CPSC’s rule stated the following: “CPSC interprets a lead-containing component part to mean the material used to construct the part includes lead in its formulation, not that the part contains smaller parts that contain lead. For example, assume that the product is a sealed ball made of plastic and that the sealed ball has a lead content that complies with the CPSIA lead limits. Inside the sealed ball are metal beads that contain lead. In this example, the metal beads are lead-containing component parts, but the ball is not. If the sealed ball does not provide access to the beads inside it, through a hole or a crevice, or after being subject to use and abuse testing, then the lead-containing parts would be deemed inaccessible.” (Federal Register 8/7/09)

But wait, there’s more good news.

In the same August 7th ruling, CPSC stated that inaccessible component parts do not have to be tested and certified as to the lead content. This means that electronics manufacturers will not be required to conduct expensive third party testing of inaccessible component parts for lead content. Using the same previous example of a sealed plastic ball containing inaccessible lead beads, this ruling eliminates the requirement to test the lead balls contained within the sealed plastic ball. CPSC’s final ruling prevents unnecessary time and cost burdens that could have been potentially levied on the electronics industry.

IPC will continue to monitor CPSC actions affecting IPC members.

To view more information about the CPSIA please visit

One Comment

  1. Posted December 4, 2009 at 6:29 am | Permalink

    Great Post..Thanks for sharing the information with us.

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