Your regular update for technical and industry information
SEPTEMBER 2020 - TOYS AND CHILDREN'S PRODUCTS
Vermont’s Department of Health has updated Chemicals of High Concern in Children’s Products Rule1 after the public hearing2 held in December last year.
The total number of Chemicals of High Concern to Children (CHCC) remains unchanged and the new rule is effective from 1st September 2020.
The new rule expands the definition of formaldehyde in the list of CHCC to include "formaldehyde donors“, which are substances that are intentionally added to release formaldehyde. The following substances are listed as examples of formaldehyde donors: 5-Bromo-5-nitro-1,3-dioxane, Bronopol, Diazolidinyl urea, DMDM hydantoin, Imidazolidinyl urea, Methanol, (phenylmethoxy), Methenamine, Quaternium-15, and Sodium N-(hydroxymethyl)glycinate.
Another change made to the rule is the reporting deadline. Previously the deadline for annual reporting was 31st August. With the latest amendments, manufacturer will be required to submit the annual report on or before 31st January 2022, and annually thereafter. In addition, a requirement to submit an interim report between annual reporting periods has been established. Manufacturer is required to submit an interim report on every 31st July for new children’s products that are introduced for sale or distribution in Vermont between 31st January and 31st July of that year.
Currently in Vermont, manufacturers of children’s products which are for children under 12 years old are required to report to the Department of Health for each CHCC annually if it is intentionally added at a level above the practical quantification limit (PQL) or present as a contaminant at a concentration at or above 100 ppm. A fee for each notice is required. The last update of the Reporting Rule was in August 20193.