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Focus On Plush Toys. Presented by: Haley Sprague and Jennifer Buoniconti UL / PPAI Product Safety Consultants. - PowerPoint PPT Presentation


  • This information is being furnished by PPAI for educational and informational purposes only. The Association makes no warranties or representations about specific dates, coverage or application. Consult with appropriate legal counsel about the specific application of the law to your business and products.

  • Plush Toy Requirements Hazardous Conditions Mechanical Safety Chemical Requirements Flammability Performance Labeling

  • Hazardous ConditionsSharp Accessible PointsNot allowed before or after use and abuse testing

    Sharp Accessible EdgesNot allowed before or after use and abuse testing

    Small PartsNo toy intended for children of all ages can be small enough, with out being compressed, to fit within the small parts cylinder

    Applicable before and after use and abuse testing

  • Mechanical Safety Bite Test Impact Test: Plush Toys Torque Test Tension Test for Seams in Plush Toys Tension Test Compression Test Material Quality Cords & Elastics Washable Toys

  • Chemical RequirementsCPSIA Ban of Lead-Containing Paint

    16 CFR 1303 in effect since 1978 at 600 ppm

    As of August 14, 2009, 90 ppm limit

    Compliance is required

    GCC/CPC is required

    Can test at ink stage, must have traceability

    Third party testing is required

    Composite Testing is allowed

    Wet paint can be tested

    HD XRF test method allowed

  • Chemical RequirementsSoluble Migrated Elements (ASTM F963)

    In surface coatings on toys, the following limits apply: - Soluble Antimony: 60 ppm - Soluble Arsenic: 25 ppm - Soluble Barium: 1000 ppm - Soluble Cadmium: 75 ppm - Soluble Chromium: 60 ppm- Soluble Lead: 90 ppm- Soluble Mercury: 60 ppm- Soluble Selenium: 500 ppm

    Note: If less than 10 mg of surface coating is present on the toy, the surface coating is exempt from Soluble testing.

  • Chemical RequirementsSoluble Migrated Elements (ASTM F963)

    In substrates of toys, the following limits apply: - Soluble Antimony: 60 ppm - Soluble Arsenic: 25 ppm - Soluble Barium: 1000 ppm - Soluble Cadmium: 75 ppm - Soluble Chromium: 60 ppm- Soluble Lead: 90 ppm- Soluble Mercury: 60 ppm- Soluble Selenium: 500 ppm

    Note: No exemption for textile materials.

  • Chemical RequirementsCPSIA Lead in Accessible Substrates

    A substrate is the material of which something is made, and to which surface coating (i.e.. paint) may be applied

    As of August 14, 2011, 100 ppm limit Compliance is requiredGCC/CPC is required Component testing is allowed, must have traceabilityThird party testing is requiredComposite Testing of like materials is allowedXRF test method allowed

  • Material Testing Exemptions Total LeadPure Wood (not plywood or other composites)PaperCMYK printing inksCertain precious and semi-precious gemstonesPearlsStainless steelPrecious metalsNatural fibers (dyed or undyed) including, but not limited to: cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, guanacoManufactured fibers (dyed or undyed) including, but not limited to: rayon, azlon, lyocell, acetate, triacetate, rubber, polyester, olefin, nylon, acrylic, modacrylic, aramid, and spandex

  • Chemical RequirementsProhibition on Sale of Certain Products Containing Specified PhthalatesApplies only to Childrens Toys and Child Care ProductsFor all such products, DEHP, DBP, BBP limit of 0.1%For all such products or any part of the product that can be placed in a childs mouth: DINP, DIDP, DnOP limit of 0.1% (interim prohibition)Applies to accessible materials only (before and after use and abuse testing)


  • CPSC Phthalate GuidancePhthalates may be found in following materials:Soft or flexible plastics, except polyolefinsSoft or flexible rubber, except silicone rubber and natural latexFoam rubber or foam plastic such as PU foamSurface coatings, non-slip coatings, finishes, decals, printed designsElastic materials on apparel, such as sleepwearAdhesives and sealantsPhthalates would not likely be found in the following materials:Unfinished metalNatural wood, except coatings and adhesives added to woodTextiles, except printed decorations, waterproof coatings, elasticMineral products such as sand, glass, crystal

  • Chemical RequirementsIllinois Lead Poisoning Prevention Act: Warning Statement Requirement

    A warning statement is required for the toys containing paint with a specified Lead content in their surface coatings

    If > 40 ppm but < 90 ppm of Lead is present, a warning statement is required


  • FlammabilityFlammability of Solids: Plush Stuffed Toys

    A product is considered to be a flammable solid if it ignites and burns along its major axis with a self-sustaining flame at a rate greater than 0.1 inches per second

  • FlammabilityFlammability of Textile Fabrics

    Plain Surface FabricsSpecimens are acceptable if they did not ignite, ignited but self extinguished or any combination thereofAverage burn time is 3.5 seconds or greater

    Raised Surface FabricsSpecimens are acceptable if they did not ignite, ignited but self extinguished or any combination thereofAverage burn time is 4 seconds or greater

  • Additional Required TestingLabeled ClaimsSamples shall perform as intended and meet all verifiable labeled claims

    Material CleanlinessLoose fillers shall be free of objectionable matter originating from, insect, bird, rodent or other animal infestation and of contaminants, such as splinters and metal chips to the extent possible in good manufacturing practice

  • Performance TestingColorfastness to CrockingAddress staining and marking concerns for fabrics that come in contact with other fabrics

    Colorfastness to WaterDetermines if a colored textile will be stained or lose color when exposed to water

    Colorfastness to SalivaDetermines the fastness of colored textiles to the affects of simulated saliva

  • LabelingCountry of Origin (19 CFR)Articles of foreign origin (or its container) imported into the United States must be marked with the name of the country of origin

    CPSIA Tracking LabelProduct and its packaging must bear a permanent distinguishing mark as required to the extent practicable

    Producer Markings (ASTM F963)Toys or their packaging must be legibly and conspicuously marked with the name and address of the producer or distributor

  • LabelingAge Grading: Plush Toys

    Toys should be labeled to indicate the minimum age for intended use or have such labeling on any packaging

    Stuffed plush toys are typically tested for the safety of all ages regardless of the age grading on the label because they are commonly recognized as appropriate for young children

  • LabelingCalifornia Proposition 65Requires the State to publish a list of chemicals known to cause cancer or birth defects or other reproductive harm.The list of chemicals can be found at businesses to provide clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemicalIntended to help Californians make informed decisions about protecting themselves from exposure to certain chemicalsConfirm with manufacturer/supplier that none of the chemicals have been intentionally added to your product

  • Summary of States Stuffed Toy Licensing and Labeling LawsUniform LabelIt is possible for manufacturers to utilize a uniform stuffed toy label which is good in all three states (Ohio, Pennsylvania and Massachusetts)There is no color, size, or type requirement for the Uniform Label, provided the print is legible and can be readily discernedThe label must be affixed to the toy itself

  • Summary of States Stuffed Toy Licensing and Labeling LawsUniform Label RequirementsThe Pennsylvania license number of the manufacturer or vendor. Ohio and Massachusetts will accept the use of a Pennsylvania toy registration number if that number if registered within these states and their fees are paidThe name and principal place of business (city and state) of the manufacturer or vendorA statement that All New Materials (with type of material) or All New (type) Material was used in the manufacture of the stuffed toy

  • Pennsylvania License Fee$25 initial registration$25 annually

    Labeling RequirementsManufacturers must submit detailed information as to the filler content of their stuffed toys and specimens of the toys selected at random to the Pennsylvania Licensing Authorities

  • Pennsylvania

    The regulation provides that stuffed toys are unfit for sale should they contain:

    Material of sufficient size to visibly reveal a pattern, weave, or other mechanical unification of threads to indicate prior use of a previous manufacturing process.Dirt and/or other foreign matter in excess of 1% by weight.More than 1 % oil or greaseMore than 0.002% LeadMore than 0.0002% Arsenic More than 5% AmmoniaMore than 1% UreaPlastic or metal ornaments such as eyes, notes etc. not of a safe design or not attached to the stuffed toys in such manner to prevent removalStones or other hard materials having jagged or sharp edgesMaterial bearing electrostatic charge with adherence characteristics which when exposed could lodge in the windpipe, ears or nostrils.Filling material which surface burns at a rate of less than 3 seconds for 12 square inches.

  • Pennsylvania

    Registration Requirements for Foreign Manufacturers

    The manufacturer may register directly with the Department at the foreign manu