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FLEXO Magazine : February 2009
PLANTS & PROCESSES There is no general requirement that packaging, or packaging inks, meet the F963 requirements specified for children's toys. Asia, where the rules and regulations for the use of toxic materials are not as well defined, or enforced. The result of this has been a general outcry by the public about government oversight and corporate responsibility. Recently, MatteI settled a $12 million civil lawsuit related to China-made toys which contained lead paint. In this case, MatteI was sued by 39 states, had to recall 2 million toys; and had to agree to more stringent lead coating standards. As part of this, and other, recalls, Congress fast-tracked new legislation to further ensure consumer protection from expo- sure to heavy metals. This legislation enacted on Aug. 14, 2008, is known as the Consumer Products Safety Improvement Act of 2008 (CPSIA). The legislation requires "importers and u.S. manufactur- ers" who put children's products on the market to verify through third party independent lab analysis that they are in compliance with Consumer Product Safety Commission (CPSC) rules. The CPSIA adopted the requirements of ASTM F963-07 as the Consumer Product Safety standard for heavy metal content. DOES NOT APPLY So, we ask again, "What do children's toy safety regulations have to do with packaging ink specification?" In fact, there is no requirement in the CPSIA legislation for packaging inks to meet these new regulations. But, since some print buyers over the years had specified ASTM F963 to be one of their proprietary require- ments, we have found significant confusion related to this new legislation. In some cases, print buyers may be asking that printers meet the new CPSIA requirements for packaging, which is not covered under the requirements of the legislation. We see the un- informed, or those who may feel this offers more protection from potential liability, asking printers to abide by the new legislation. This privately expanded use of CPSIA is unwarranted in rela- tion to packaging printed in North America. Printers, and inks suppliers, in North America are already meeting stringent require- ments related to toxic substances used in our products. Insisting on compliance with CPSIA would unnecessarily increase cost and delay shipments. A key concern with the CPSIA legislation when expanded to packaging inks is the requirement for third party testing and certification. The lab testing and certificate issuance is not a one-time activity. Rather, the manufacturer or importer CPSIA regulation does not affect or apply to packaging, unless the packaging is considered part of the toy itself. must establish a routine method of lab verification and certificate issuance on a statistically representative sampling of every piece manufactured or imported. A manufacturer or im- porter will no longer be able to solely rely upon "product guarantees" or certificates from its ven- dors to confirm that they are in compliance with CPSIA and the ASTM Toy Specifications. Actual metals analyses for the final prod- uct must be conducted by a CPSC (Consumer Product Safety Commission)- approved laboratory. In the past, offering toy safety (ASTM F963) compli- ance assurances to print buyers was a relatively sim- ple matter of formulating inks without the specified heavy metals; but providing certification for compli- ance to the new CPSIA will be extremely difficult and very expensive due to the third-party certification requirement. Therefore, print buyers need to seriously re-evaluate extending the use of CPSIA as an ink specification for products not covered under the CPSIA legislative mandate. On the surface, it may seem prudent to raise the bar on heavy metal verification, but heavy metal contamination has not been a problem related to products manufactured in North America already covered by exist- ing legislative requirements. In addition to the issue raised in the CPSIA related to heavy metals, the legislature also bans the use of several phthalate plas- ticizers in children's toys and child care products. Again, this leg- islation does not cover packaging, or packaging inks. Extending these toy and child care requirements to packaging will create additional costs, and add a burden to the supply chain. As consumers, we want to be assured that children's toys and child care products are safe. And as manufacturers, we certainly accept the need to provide this protection to the public. This legislation was needed and was written and enacted to address a very real problem. However, we do not want to extend and ex- pand this legislation to areas for which they were not intended. . HIGHLIGHTS OF THE CPSIA . A lead content limit for chil- dren's products which likely applies retroactively begins on Feb. 10, 2010, with lower lead content limits coming on line over the next few years; · A Certificate of Conformity requirement for all consumer products that are regulated in any manner under u.S. con- sumer product safety laws; · Mandatory third party test- ing and certification for all children's products; · A ban on certain phthalates in children's toys and child care articles begins on Feb. 10, 2010; · Permanent tracking label re- quirements for all children's products; and · Hazard warning require- ments for advertisements of certain toys and children's products. FEBRUARY 2009 - www.f I exog ra p hy.o rg FLEXO
Sustainable Winter 2009