Individual International Plastics Inc Standards and Protocol Review

Table of Contents

Overview

• Testing and Certification
• Updates and Revisions to ASTM F963
• Additional Resource

Specific Testing Questions

• Labeling and Product Marking
• Flammability
• Lead and Heavy Metals
  

Overview

All toys intended for use by children 12 years of age and under must be third political party tested and exist certified in a Children's Product Document as compliant to the federal toy rubber standard enacted by Congress, and to other applicable requirements too. Please see our Business Guidance Folio. Also, please come across guidance pages for other common requirements for children's products: lead, atomic number 82 in pigment, phthalates, pocket-size parts, and tracking labels.

What is the toy safety standard?

The toy safety standard refers to ASTM F963-17, as incorporated with a modification shown in 16 CFR Part 1250. All children'southward toys manufactured or imported on or after February 28, 2018, must be tested and certified to ASTM F963-17.

ASTM F963-17,The Standard Consumer Safety Specification for Toy Prophylactic, is a comprehensive standard addressing numerous hazards that take been identified with toys. In 2008, the Consumer Product Prophylactic Improvement Act of 2008 (CPSIA) mandated that the voluntary toy condom standard in effect at that time get a nationwide mandatory children's product safety dominion.

You may view a summary of the ASTM toy safe standard and purchase the standard in its entirety from ASTM International'southward website.  On ASTM'southward website, you can view a brief description of the toy safety standard, a tabular array of contents of the standard's sections, and a listing of products that are not covered by the toy safety standard (although some of those products, such as bicycles, are covered by another mandatory standard). To view the full standard, y'all must buy the copyright-protected document from ASTM by visiting astm.org. Please note, a manufacturer or importer of children's toys is responsible for identifying the sections of the toy standard that utilise to their company's product(due south).

Are third party testing and certification required for the toy safety standard?

Yes. Third party testing and certification are required for toys designed or intended primarily for children 12 and nether. In one case yous accept identified the applicative requirements for your product, you must use a CPSC-accepted laboratory to perform testing to show that the product complies with the toy standard.

To facilitate the testing of your product, y'all should contact a CPSC-accepted laboratory to talk over your production and to secure an guess. The estimate should provide you with an itemized list of which sections of the standard the laboratory proposes to test your product to for conformity. (As a consumer of such laboratory services, you may want to secure an estimate from more than than i laboratory, as you probable would do with any major purchase.)

Does every section of the toy safety standard apply to every toy?

No. The toy safety standard is a lengthy document that contains provisions for many unlike types and classes of toys.There is no ane-size-fits-all approach to the toy standard.  Unlike sections of the toy standard apply to different toys.  Many of the standard's sections may not utilise to a detail product, but there are likely to exist many sections that do apply.

For example, if your toy does not produce whatever sound, it would not need to comply with the department of the toy standard that tests how loud a sound the toy makes; however, in that location are nevertheless many other provisions of the toy standard that may apply to your toy.  Because dissimilar toys have different characteristics, materials, and functions, every toy needs to exist reviewed individually to determine what sections of the standard are applicable.

As a manufacturer or importer, it is your responsibility to review the toy safe standard and to consider which sections of the standard may apply to your production. (You may review the table of contents gratis of accuse.)  Ultimately, yet, yous will likely need to accept your production tested past a CPSC-accepted laboratory. Delight review these helpful questions to ask the laboratory.

Delight see this helpful nautical chart on ASTM F963-17 that breaks downward the different sections of the toy standard into generally applicable requirements and toy-specific requirements.

Testing and Certification

Do all sections of the toy safety standard include third party testing requirements?

No, simply certain provisions of the toy safety standard outlined in 16 CFR §1112.fifteen(b)(32), and as well detailed in this nautical chart, specify 3rd political party testing requirements. The sections of the toy safe standard thatcrave third party testing are:

ASTM F963-17

• Section 4.3.5.1, Surface Coating Materials - Soluble Test for Metals
• Section four.3.v.2, Toy Substrate Materials
• Section 4.3.6.iii, Cleanliness of Liquids, Pastes, Putties, Gels, and Powders (except for cosmetics and tests on formulations used to preclude microbial degradation)
• Section 4.3.seven, Stuffing Materials
• Department 4.v, Sound Producing Toys (requirements for this section modified by 16 CFR part 1250)
• Department 4.6, Small Objects (except labeling and/or instructional literature requirements)
• Section 4.7, Attainable Edges (except labeling and/or instructional literature requirements)
• Department 4.8, Projections
• Section 4.9, Accessible Points (except labeling and/or instructional literature requirements)
• Section 4.x, Wires or Rods
• Section iv.11, Nails and Fasteners
• Section four.12, Plastic Film
• Department 4.13, Folding Mechanisms and Hinges
• Section 4.fourteen, Cords, Straps, and Elastics
• Section four.fifteen, Stability and Overload Requirements
• Section 4.sixteen, Confined Spaces
• Section 4.17, Wheels, Tires, and Axles
• Section 4.18, Holes, Clearances, and Accessibility of Mechanisms
• Department four.19, Simulated Protective Devices (except labeling and/or instructional literature requirements)
• Section four.20.1, Pacifiers with Rubber Nipples/Nitrosamine Test
• Department 4.20.2, Toy Pacifiers
• Section four.21, Projectile Toys
• Section iv.22, Teethers and Teething Toys
• Section iv.23.1, Rattles with Nearly Spherical, Hemispherical, or Circular Flared Ends
• Section 4.24, Squeeze Toys
• Department 4.25, Battery-Operated Toys (except labeling and/or instructional literature requirements)
• Section 4.26, Toys Intended to Be Attached to a Crib or Playpen (except labeling and/or instructional literature requirements)
• Section 4.27, Stuffed and Beanbag-Type Toys
• Department 4.30, Toy Gun Marking
• Section four.32, Sure Toys with Spherical Ends
• Section 4.35, Pompoms
• Section 4.36, Hemispheric-Shaped Objects
• Section iv.37, Yo-Yo Elastic Tether Toys
• Section four.38, Magnets (except labeling and/or instructional literature requirements)
• Department 4.39, Jaw Entrapment in Handles and Steering Wheels
• Section 4.40, Expanding Materials
• Section iv.41, Toy Chests (except labeling and/or instructional literature requirements)

The sections of the toy safety standard that DO Non require third political party testing by the CPSC are as follows:

• The sections of ASTM F963 pertaining to the manufacturing process, and thus, toys cannot exist evaluated meaningfully by a exam of the finished product (east.thousand., the purified water provision at section 4.3.6.1).
• Requirements for labeling, instructional literature, or producer's markings in ASTM F963. More information on this issue below in a separate FAQ.
• Generally, the Commission has stated that it volition non require 3rd party testing and certification for sure labeling and technical requirements. For example, neither the labeling requirements under the Federal Chancy Substances Act (15 U.Due south.C. 1261−1278), nor the labeling requirements under the Flammable Fabrics Deed (15 U.S.C. 1191−1204) require a product to undergo tertiary party testing.
• The sections of ASTM F963 that involve assessments conducted past the unaided center and without whatever sort of tool or device.
  

Do all sections of the toy safe standard require certification?

Yes. Although certain sections of the toy safety standard are exempted from third party testing, toys must be certified, in a Children's Production Certificate, as existence fully compliant withall applicative sections of the toy condom standard. For the sections of the toy safety standard that are exempt from 3rd party testing, manufacturers are still expected to ensure that their product is compliant with those applicable sections and to certify compliance through a Children'southward Product Certificate roofing the production.

Where can I observe the official Committee Discover of Requirements and the 3rd party testing requirements for children's toys?

The specific sections of the toy rubber standard that require testing at a CPSC-accepted testing laboratory are listed at 16 CFR §1112.15(b)(32).

For which age groups (i.e., the product'southward intended users) are 3rd party testing and certification of toys required?

Toys intended or designed primarily for children 12 years of age or younger must exist 3rd party tested past a CPSC-accustomed testing laboratory and certified past the manufacturer or importer in a Children'southward Product Document.

Although ASTM F963 applies to toys intended for utilize by children under 14 years of historic period, federal law requires third party testing for items subject to children's production safety rules. The law defines "children's products" as consumer products designed or intended primarily for children 12 years of age or younger.

Specific Testing Questions

Do alarm labels, written pedagogy manuals, or other producer's markings on a product or the product'due south packaging require testing by a CPSC-accepted laboratory?

No. In improver, the sections of ASTM F963 that involve assessments conducted by the unaided eye and without any sort of tool or device do non crave testing by a CPSC-accustomed laboratory. See the complete list of sections that crave tertiary party testing, described in the bulleted list above. If a department from ASTM F963 is not listed there, then tertiary party testing is not required.

Are toys required to exist tested to meet flammability requirements?

No. Congress did not include flammability requirements and tertiary political party testing for toys when it made the toy safe standard mandatory in 2008.

However, a children's toy—during its customary and reasonably foreseeable handling or utilize—must non be a chancy substance that may crusade substantial personal injury or substantial illness during, or as a proximate result of, existence a highly combustible or extremely flammable solid. This requirement, which is from the Federal Chancy Substances Human action, does not crave premarket, 3rd party testing from a CPSC-accepted laboratory.

This means that there may be situations when a children'south toy that is likely to be used in or around a flame source, volition need to exist tested to ensure that the production is not highly or extremely flammable. If a manufacturer is uncertain, or wishes to test the product to be certain it is non highly flammable, sixteen C.F.R. § 1500.44 is an appropriate test method to apply, and the test method provided in Annex A5 of ASTM F963 is some other advisable test method.

Must all accessible substrates be tested for total lead and soluble heavy elements, every bit specified in ASTM F963-17?

Not necessarily. Although section 4.3.5.2(i) of ASTM F963-17 says that the accessible substrates and all small parts must be tested for total lead and eight soluble heavy elements, the term "accessible" is divers in 4.three.5.2(1)(a), and information technology is very important to determine whether your toy is bailiwick to this additional requirement.

Start, "accessible" is defined in section 3.1.2 of ASTM F963-17, and a toy must be examined for accessible parts both before and after age-appropriate utilise and corruption testing.

Second, for the purpose of the definition in section 3.ane.2, and as stated in section 4.3.5.two, but toys, or the parts of toys that can exist sucked, mouthed, or ingested--both before and after age-appropriate apply and corruption testing--need to be tested for the viii soluble heavy elements . This ways that toys, or parts of toys that, due to their inaccessibility, size, mass, function, or other characteristics, cannot be sucked, mouthed, or ingested, are not required to be tested for the soluble elements listed above. Notwithstanding, compliance with full atomic number 82 content limits for such items nonetheless may be required under the CPSIA, if they are accessible to bear on.

The following criteria are considered reasonable for the classification of toys that are likely to be sucked, mouthed, or ingested: (one) all toy parts intended to be mouthed or contact food or drink, components of toys which are cosmetics, and components or writing instruments categorized as toys; (2) toys intended for children less than six years of age, where there is a probability that the parts or components of the toy would come into contact with the mouth. See Note four of Section 4.3.five.2(one)(a).

Therefore, if your production is historic period-graded as intended for use for children age half-dozen years and above, and is not likely to be sucked, mouthed, or ingested, it does not need to be tested for the eight metals. Recall that regardless of this analysis, the CPSIA requires that all accessible components of children'due south products meet the lead content requirement of 100 ppm. Please review our lead guidance folio.

Commission Determinations Regarding Heavy Elements Testing: The CPSC has determined that children's toys made exclusively of any combination of the following materials do not need to be tested to ASTM F963'due south Department four.3.five.twoHeavy Elements: Toy Substrate Materials past a tertiary-party laboratory:

1. Unfinished and untreated wood (run across 16 CFR §1251.2);
2. Engineered wood products made from particleboard, hardwood plywood, or medium-density fiberboard (run into 16 CFR §1252.3(b)); and/or
3. Unfinished manufactured fibers that are untreated and unadulterated – nylon, polyurethane (spandex), viscose rayon, acrylic or modacrylic, and natural prophylactic latex (run into 16 CFR §1253.two(b)).

Cadmium

Section 4.three.5.ii(one) states that the accessible substrates in toys (including attainable drinking glass, metal, and ceramic toys or pocket-size parts of toys) are subject to the limits gear up forth in Table 1 of F963-17, which specifies, amid other requirements, a limit of 75 parts per 1000000 of soluble cadmium content (or 50 parts per million for modeling clays that are part of toys). However, Department 4.3.v.2(2)(c) states that the soluble cadmium content limit is 200µg.

What is the difference between these two requirements? The test process for the requirement in department four.3.5.2(1) is based on a 2-60 minutes extraction catamenia. Section 4.3.5.2(2)(c) specifically states that the section is in add-on to the limits in Tabular array i, just only for metallic toys or metallic toy components that are modest parts. That class of toys cannot exceed a value of 200 µg for total cadmium extracted from an item within a 24-60 minutes flow when tested per section 8.iii.5.5(3). The section does note, nonetheless, that "Compliance with all of the higher up requirements may be established by a screen of full element content as specified in 8.3.1."

Updates Revisions to ASTM F963

What are the key changes in the newest version of the CPSC'southward toy safe standard, ASTM F963-17?

Projectile Toys

The latest revision to ASTM F963 corrected language from the 2016 version apropos the testing of projectile toys in section 4.21.ii.3. This change was made to bring section 4.21.ii.three into harmony with the intent of the March 31, 2017, CPSC staff enforcement discretion letter concerning that section.

Sound-Producing Toys

The regulation at xvi CFR part 1250 requires toys to comply with applicable provisions of ASTM F963-17, with one exception relating to toy examination methods on audio-producing pull/push toys institute in Section 8.20.one.five(five). The regulation at xvi CFR § 1250.2(c) indicates that toys, instead of complying with Section 8.20.i.5(5) of ASTM F963-17, must comply with the post-obit:

Flooring and tabletop toys that move, where the sound is caused as a effect of the motion imparted on the toy (for example, a noise-making mechanism attached to an axle of a toy vehicle) shall be tested using the method for pull and push toys. In addition to the C-weighted peak measurement maximum A-weighted sound pressure level level, L _AFmax, shall exist made and compared to the requirements of 4.5.1.2.

Other

The majority of the changes made to ASTM F963-17 were editorial changes: grammar and spelling changes, and clarifications to sentences. Other changes were made to some terminology: one definition was removed, 1 was clarified, i was changed editorially, and there were nine new references that were added that relate to microbiological guidelines. There was a rationale that was added in reference to the new language in section 4.21.2.three for Projectiles with Stored Energy.

What were the cardinal changes from the 2011 version to the 2016 version of CPSC's toy safety standard, ASTM F963?

Labeling Requirements

Battery-Operated Toys and Magnetic Toys received new labeling requirements. Run across Sections 5.15 for push or coin prison cell batteries and 5.17 for magnets.

Batteries

ASTM F963-xvi incorporated new testing requirements on certain push and coin cell batteries of ane.5V+. There are 4 new testing methods – overcharging, repetitive overcharging, single-mistake charging tests and short-circuit protection examination.  Meet section 8.xix.

Heavy Elements

ASTM F963-16 updated the testing methodology for heavy elements to allow X-ray Fluorescence Spectrometry using Monochromatic Excitation Beams (HDXRF) for full element screening.  See Section 8.three.one.four.

Magnets

The 2016 version of the toy standard included a circadian soaking test for but wooden toys, toys to exist used in water, and mouth pieces of mouth-actuated toys with magnets or magnetic components.  Encounter Section 8.25.four.

Mouth-Actuated Toys

ASTM F963-sixteen added design requirements to prevent projectiles from entering the mouth.  See Section 8.thirteen.ii.

Projectile Toys

Kinetic free energy density level changes allowed for sure types of projectile toys. Of detail notation, CPSC staff issued a letter on March 31, 2017, exercising its enforcement discretion under section four.21.two.3, to use the KED requirements merely to projectiles with energies greater than 0.08 J. This enforcement discretion extends to testing and certification requirements under Section 14 of the Consumer Product Prophylactic Human action (CPSA), fifteen U.s.a.C. § 2063, and so that testing would not be required for projectiles with energies less than or equal to 0.08 J. This enforcement discretion went into effect immediately, and it will remain in effect until further notice. Please read the full letter of the alphabet for more information, and see Section 8.xiv of the Toy Standard.

Ride-On Toys

Design changes:

• Stability – dimensional spacing between wheels on the aforementioned axis, see Section 4.15.1.
• Overloading – more stringent overload weight test for ride-on and seated toys, see Section 8.28.
• Restraints – exempts straps used for waist restraints from free length and loop requirements, see Section four.xiv.6,

Sound-Producing Toys

Redefined "oral fissure-actuated toys" to include broader range of toys (run across Section 4.5):

• increases peak limits (meet Department four.v.1.4 and Annex A12.9.four);
• lowers test speed for push-pull toys (see Section 8.twenty.2.five and Addendum A12.9.x)

Sections added in ASTM F963-xvi

• Toy Chests (Section 4.41) – Reincorporated toy chest sections 4.27 and associated provisions from ASTM F963-07ε1; clarified a multi-positional lid requirement when testing for maximum chapeau drib.

• Expanding Materials (Department 4.twoscore) – new definitions, performance requirements, test methodology and a test template to accost the emerging hazard of GI blockage related to ingestion of expanding materials

Note, several of the new or revised requirements in the release of the 2016 version of ASTM F963 are intended to align ASTM F963, ISO 8124 and EN71 toy standards. Additionally, the changes listed above are simply selected changes to the U.S. Toy Standard, ASTM F963-xvi version.

If you are non sure how these changes affect your product, you tin contact the CPSC Small Concern Ombudsman for assist past emailing us here: https://www.cpsc.gov/About-CPSC/Contact-Information/Contact-Specific-Offices-and-Public-Information/Small-Business organization-Ombudsman, or by calling 301-504-7945.

For hereafter updates to ASTM F963, what happens when ASTM International submits proposed revision(s) to the Commission regarding the ASTM F963 toy standard currently in effect?

When ASTM International notifies the Commission of proposed revision(s) to ASTM F-963, the Commission has 90 days from the date of notification to inform ASTM International if information technology determines that the proposed revision(s) does not amend the condom of the consumer product covered past the standard.

If the Committee informs ASTM International of its determination that the proposed revision(s) does not improve safety, the existing ASTM F963 standard continues in effect as a consumer product rubber rule, regardless of the proposed revision(s).

If the Commission does not respond to ASTM International within 90 days regarding the proposed revision(s) to ASTM F963, 90 days later on (180 days total afterward notification past ASTM International), the proposed revision(southward) becomes effective equally a consumer product safety dominion.

Additional Resources

• ASTM F 963-17 Chart

For more than data, please contact the U.South. Consumer Product Prophylactic Committee:

1. Role of Compliance (for specific enforcement inquires): email: section15@cpsc.gov; telephone: (800) 638-2772.
2. Small Business Ombudsman (for general help agreement and complying with CPSC regulations): e-mail: Please use our Contact Course, which is the best mode to get a fast response; telephone: (888) 531-9070.

This communication has been prepared for general informational purposes only and is based upon the facts and information presented. This communication does non, and is non intended to, institute legal advice and has non been reviewed or canonical by the Commission, and does not necessarily represent their views. Any views expressed in this advice may exist changed or superseded past the Commission.

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Source: https://www.cpsc.gov/Business--Manufacturing/Business-Education/Toy-Safety-Business-Guidance-and-Small-Entity-Compliance-Guide

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