The Vermont Department of Health recently implemented the reporting requirements for chemicals of high concern in children’s products that the state enacted into law in June 2014(Act 188, relating to the regulation of toxic substances).

Background   

Pursuant to 18 V.S.A § 1776, Manufacturers who use chemicals designated by the state of Vermont as chemicals of high concern to children must disclose information about these chemicals to the Department of Health beginning on 1 July 2016 and biennially thereafter if the chemicals (1) have been intentionally added to a children’s product at a level above the practical quantification limit(PQL) produced by the manufacturer, or (2) are present in a children’s product produced by the manufacturer as a contaminant at a concentration of 100 ppm or greater.

Main Requirements

Children’s products subject to these reporting requirements include (1) toys; (2) children’s cosmetics; (3) children’s jewelry; (4) products designed or intended by the manufacturer to help a child with sucking or teething, to facilitate sleep, relaxation, or the feeding of a child, or to be worn as clothing by children; and (5) child car seats.

Vermont has designated the following 66 chemicals as chemicals of high concern, such as formaldehyde; aniline; N-nitrosodimethylamine; benzene; vinyl chloride and so on.

According to the new regulations, required notices will have to include the following information:

(1) The name of the chemical used or produced and its chemical abstracts service registry number;

(2) A description of the product (including the Global Product Classification product brick description) or product component containing the chemical;

(3) The amount of the chemical contained in each unit of the product or product component, reported by weight or parts per million as authorized by the commissioner;

(4) The name and address of the manufacturer of the children's product as well as the name, address and telephone number of a contact person for the manufacturer;

(5) Any other information the manufacturer deems relevant to the appropriate use of the product;

(6) the function of the chemical in the product; and

(7) The brand name and product model.

A US$200 fee will be collected for each notice filed with the Vermont Department of Health.

Reporting Deadline 

The reporting deadline is Jul 01, 2016, However, Vermont authorities advise that the new on-line chemical reporting system is not currently operational and is not anticipated to be up-and-running until the spring 2016. Accordingly, manufacturers will be given six months from the date of the system’s availability to file the required reports, which means that the reports may conceivably be filed after the 1 July 2016 deadline.

BACL Suggestion  

In order to avoid the penalty and economic loss caused by violation of the law, BACL suggests that all manufacturers of children’s product which will be sold in Vermont, should pay attention to the law and follow the reporting procedure. You also should pay close attention to the 66 chemicals of high concern in the list and minimize the intentional use of these chemicals of high concern.

BACL Service

BACL is a comprehensive, professional and international third part laboratory that can provide testing, inspection, and certification to the consumer products industry. Moreover, we would also provide comprehensive quality solution to facilitate manufacturers in the global market.

For the details, please click the link: http://healthvermont.gov/enviro/chemical/cdp.aspx

For PQL, please click the link: http://healthvermont.gov/enviro/chemical/documents/PQL.pdf

For List of Chemicals of High Concern to Children, please click the link:

http://healthvermont.gov/enviro/chemical/documents/chemicals_of_high_concern_to_children.pdf