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In This Issue:
• CPSIA 2008 affects publishers of Children’s
Books
— Introduction: New regulations on lead and Phthlates
— Effect on Book Publishing industry
— Managing the new rules when printing in China
• Case Study: Okidokie Sounds For Silence
• Meet the Staff: Alan Shao
• Upcoming Events: Book Expo America and others
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China Printing News, Tips on China Print Production
& Case Studies |
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The
CPSIA 2008 Imposes Limits on Lead, Phthalates in Children's
Books
1. Background
Introduction - New regulations for heavy metals and
phthalates in Children’s products
The Consumer Product Safety Improvement Act (CPSIA)
of 2008 establishes specific limits on lead in children's
products. Under section 101(a) of the CPSIA, products
designed or intended primarily for children 12 years
of age or younger may not contain more than 600 ppm
of lead by weight for any part of the product after
February 10, 2009, may not contain more than 300 ppm
after August 14, 2009, and 100 ppm after August 14,
2011, unless the Commission determines that it is not
technologically feasible to have this lower limit.
In tandem, section 108 of the CPSIA 2008 permanently
bans children's toys and child care articles containing
more than 0.1% of three specific phthalates and on an
interim basis bans children's toys and child care articles
than can be placed in the mouth which contain more than
0.1% of 3 additional phthalates. Starting on February
10, 2009, these products can no longer be sold, offered
for sale, manufactured or imported for sale to the United
States unless they adhere to the new law.
The law further specifies the requirements of manufacturer
certificates and 3rd party testing to demonstrate compliance.
To view the completeFederal register publication on
Section 101a, click
here
To view a complete CPSC advisory on Section 108 click
here
To view a detailed timetable of limits and effective
dates, click
here
To visit the CPSC website, click
here
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Summary:
• Lead limits for books specifically
designed for children, or with inherent play value ONLY.
•
Printing Ink is not paint
•
Book-Toy Combinations and Books with Play Value are
subject to Section 108 restrictions
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2.
Effect of CPSIA 2008 on Publishing Industry
After requests for clarification from the Association
of American Publishers and others, the Consumer Product
Safety Commission (CPSC) issued guidance on the applicability
of the CPSIA 2008 to books and similar products.
In a letter dated December 23, 2008 CPSC General Counsel
Cheryl A. Falvey stated that books intended for reading
by the general public (including children), by definition
"are not intended or designed primarily for children.
Therefore those books do not need a general conformity
certification for lead content and do not require third-party
testing of any kind."
While that is considered legal opinion and not an approved
exemption by the Commission, it is now generally believed
that books and other publication are NOT required to
comply with the lead guidelines of CPSIA 2008 UNLESS
they are specifically designed for children or have
inherent play value.
As for Section 108 covering phthalates, the same advisory
states that "ordinary books ....are reading materials
and not toys and, therefore, the phthalates provisions
of the CPSIA do not apply to them." It is clear
then that books which DO have play-value (for instance
vinyl bath books or books with removable die cut shapes),fall
under the guidance of Section 108.
To read the full text of Ms. Falvey's letter: click
here
Highlights of the advisory opinion on lead and phthalates
in books and relevant compliance deadlines are summarized
in the table below:
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| Book
Product/ Description |
Substance |
Requirement |
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Books intended or designed
primarily for children
(whether ordinary books or books with inherent
play value) |
Lead Content |
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011) |
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Books intended
or designed primarily for
children that have some inherent play value
or components with inherent play value |
Lead Content |
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011) |
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Phthalates |
≤ 0.1% DEHP, DBP or
BBP
≤ 0.1% DIDP, DINP or DNOP
(if can be placed in the mouth) |
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Toy (sold together
with an ordinary book) |
Lead Content |
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011) |
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Phthalates |
≤ 0.1% DEHP, DBP or
BBP
≤ 0.1% DIDP, DINP or DNOP
(if can be placed in the mouth) |
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3.
Managing the New Rules when Printing in China
Keeping pace with the times, China Printing Solutions
International has fully studied the new CPSC regulations
in order to support not only its American publishing clients,
but those International publishers who may wish to sell
their product in the United States. After careful consideration,
CPS has established the following process to ensure compliance
with CPSIA 2008 guidelines. In addition to provision of
Manufacturer's Certification of general conformity, the
following tests are available at this time:
I. Ordinary Children's Books:
- Final product tested only
- Test time required: Normally 5-7 days
- Charges: $20.00/element (Example: test ink, paper, board,
lamination and Head/Tail bands, totally 5 elements with
$100.00 charged.)
- Client will get a formal accredited 3rd party report
showing the book complies with “the Lead Requirement
of US Public Law 110-314 [HR 4040 ‘Consumer Product
Safety Improvement Act of 2008]”
II. Children's Books with inherent play value
or toy component:
- Final product tested only
- Test time required: Normally 5-7 days
- Charges: $155.00/element
- Client will get a formal accredited 3rd party report
showing the book complies with “the Lead Requirement
of US Public Law 110-314 [HR 4040 ‘ Consumer Product
Safety Improvement Act of 2008]” and “the
Phthalate Requirement of US Public Law 110-314 [HR 4040
‘Consumer Product Safety Improvement Act of 2008]”
Fees and lead time are subject to change.
If you have any questions about this procedure, or wish
to discuss further, please email us at: info(at)chinaprintingsolutions.com |
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Case Study:
Okidokie
Sounds For Silence
Client: Okiedokie
Pty Ltd. (Australia)
Project Name: Sounds for Silence
Description: Sounds for Silence is a CD of
sounds specially designed by an Australian pediatrician
which has been proven to aid in helping babies sleep.
Previously sold in a PVC pouch, the product needed an
upgrade in accordance with the company’s interest
to sell it internationally. CPS designed a hardback
CD sleeve and cloth covered slipcase to hold the product
components in a classy, high value product. A big success,
the initial print run of a few thousand pieces was quadrupled
in the second order.
For
More Case Studies, Please Click Here
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Meet
the Staff:
Alan Shao
I Production Manager
Hailing from AnHui, a province neighboring Shanghai,
Alan Shao holds both an Undergraduate and a Master’s
degree in printing technology. In the 10 years course
of his career he has worked in a variety of roles in
offset printing, including jobs as a Press operator,
as a materials purchaser and in sales.
In his current role for CPS as Production Manager, Alan
supervises a team undertaking new estimates, material
and machine specifications, quality assurance and scheduling.
Drawing on a deep understanding of the printing process
and a wide network of supply contacts throughout China,
Alan routinely proposes process improvements that increase
quality and reduce cost.
Cheerful and optimistic by nature, Alan is a former
University league Soccer star, and still enjoys a good
match on his days off, away from the buzz of printing
machinery.
Alan can be reached at ashao(at)chinaprintingsolutions.com.
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| USA
TOLL FREE: |
US-CHINA
DIRECT: |
EUROPE
(UK): |
AUSTRALIA |
| +1.877.CPS.3933 |
+1.314.266.0741 |
+44.(0)20.7193.0741 |
+61.(0)3.9018.5729 |
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