Children's Safe Products Act reporting guidance

Manufacturers must report the presence and use of certain chemicals in children's products offered for sale in Washington each year according to the Children's Safe Products Reporting Rule (Chapter 173-334 WAC):

The next reporting deadline is Jan. 31, 2023.
There are no fees for reporting children's products in Washington state.

I want to...

Do you need to report?

To help you determine who needs to report, if you can answer Yes to each of the following questions, then you must report:

Are your products offered for sale in Washington state, either in a store or online?
Are your products defined as children’s products according to the regulations?
Do your products contain one or more chemicals of high concern to children (CHCCs)?
Are you the manufacturer responsible for reporting?

If you answered No to any of the above questions, you do not need to register or report.

When are reports due?

The next reporting deadline is Jan. 31, 2023. This is for products offered for sale in Washington from Jan. 1, 2022 to Dec. 31, 2022.

What do you need to report?

Manufacturers must report products that contain one or more CHCCs. For each CHCC, include the “function set,” which is the unique combination of the following product information:

Product category or "brick" is a Global Product Classification (GPC) product description. GPC identifies products that serve a common purpose, are of a similar form and material, and share the same set of category attributes.

Submit one report for all products that fit into a product category.
A drop-down list of children’s product categories is available in the reporting platform.

Product component is the uniquely identifiable material or coating of the product. Choices for product components were developed in consultation with product testing laboratories and are available for you to select when you file your report:

Indicate which product component contains CHCCs.
You do not need to report on “internal components" (as defined in Chapter 173-334-040 WAC).

Report the highest amount of each CHCC found in a product component in each product category. You can report in ranges rather than the exact amount, based either on test results or manufacturing knowledge.

If the CHCC is present as a contaminant:
Report any amount above 100 parts per million (ppm), unless you have a manufacturing control program in place and exercise due diligence to minimize the level of the contaminant.
If the CHCC is intentionally added:
Report any amount above the practical quantitation limit (PQL). Use the table below to help you determine target level PQLs.

Chemicals and the target level PQL

Table of chemicals, CAS number, and target PQL levels
#	Chemical	CAS	Target Level PQL (ppm)
1	Formaldehyde	50-00-0	5.0
2	Aniline	62-53-3	1.0
3	N-Nitrosodimethylamine	62-75-9	1.0
4	Benzene	71-43-2	1.0
5	Vinyl chloride	75-01-4	0.5
6	Acetaldehyde	75-07-0	1.0
7	Methylene chloride	75-09-2	1.0
8	Carbon disulfide	75-15-0	1.0
9	Methyl ethyl ketone	78-93-3	1.0
10	1,1,2,2-Tetrachloroethane	79-34-5	1.0
11	Tetrabromobisphenol A (TBBPA)	79-94-7	50.0
12	Bisphenol A (BPA)	80-05-7	1.0
13	Bisphenol S10 (BPS)	80-09-1	1.0
14	Dicyclohexyl phthalate10 (DCHP)	84-61-7	25.0
15	Diethyl phthalate (DEP)	84-66-2	25.0
16	Diisobutyl phthalate10 (DIBP)	84-69-5	25.0
17	Di-n-butyl phthalate (DBP)	84-74-2	25.0
18	Di-n-hexyl phthalate (DnHP)	84-75-3	25.0
19	Butyl benzyl phthalate (BBP)	85-68-7	25.0
20	N-Nitrosodiphenylamine	86-30-6	1.0
21	Hexachlorobutadiene	87-68-3	5.0
22	Propyl paraben	94-13-3	5.0
23	Butyl paraben	94-26-8	5.0
24	2-Aminotoluene	95-53-4	1.0
25	2,4-Diaminotoluene	95-80-7	1.0
26	Methyl paraben	99-76-3	5.0
27	4-Hydroxybenzoic acid	99-96-7	5.0
28	Ethylbenzene	100-41-4	1.0
29	Styrene	100-42-5	1.0
30	4-Nonylphenol	104-40-5	10.0
31	4-Chloroaniline	106-47-8	1.0
32	Acrylonitrile	107-13-1	1.0
33	Ethylene glycol	107-21-1	40.0
34	Toluene	108-88-3	0.5
35	Phenol	108-95-2	1.0
36	2-Methoxyethanol	109-86-4	10.0
37	Ethylene glycol monoethyl ether	110-80-5	10.0
38	Triphenyl phosphate10 (TPP)	115-86-6	50.0
39	Tris(2-chloroethyl) phosphate (TCEP)	115-96-8	50.0
40	Di-(2-ethylhexyl) phthalate (DEHP)	117-81-7	25.0
41	Di-(2-methoxyethyl) phthalate10 (DMEP)	117-82-8	25.0
42	Di-n-octyl phthalate (DnOP)	117-84-0	25.0
43	Hexachlorobenzene	118-74-1	1.0
44	3,3´-Dimethylbenzidine & Dyes Metabolized to same	119-93-7	1.0
45	Ethyl paraben	120-47-8	5.0
46	1,4-Dioxane	123-91-1	20.0
47	Tris (2,3-dibromopropyl) phosphate10 (TDBPP)	126-72-7	50.0
48	Tri-n-butyl phosphate10 (TNBP)	126-73-8	50.0
49	Tetrachloroethene	127-18-4	0.5
50	Dipentyl phthalate10 (DPP)	131-18-0	50.0
51	Benzophenone-2 (Bp-2)	131-55-5	5.0
52	4-tert-Octylphenol	140-66-9	10.0
53	Estragole	140-67-0	10.0
54	2-Ethylhexanoic acid	149-57-5	5.0
55	Perfluorooctanoic acid and related substances10 (PFOA)	335-67-1	0.001
56	Pentachlorobenzene	608-93-5	1.0
57	Bisphenol F (BPF)10	620-92-8	1.0
58	C.I. Solvent Yellow 14	842-07-9	1.0
59	N-Methylpyrrolidone	872-50-4	1.0
60	Decabromodiphenyl ether (BDE-209)	1163-19-5	50.0
61	Ethylhexyl diphenyl phosphate10 (EHDPP)	1241-94-7	50.0
62	Tricresyl phosphate10 (TCP)	1330-78-5	50.0
63	Perfluorooctane sulphonic acid and its salts (PFOS)	1763-23-1	0.001
64	4-Octylphenol	1806-26-4	10.0
65	2-Ethyl-hexyl-4-methoxycinnamate	5466-77-3	5.0
66	Mercury & mercury compounds	7439-97-6	0.5
67	Antimony & Antimony compounds	7440-36-0	1.0
68	Arsenic & Arsenic compounds including arsenic trioxide (1327-53-3) & dimethyl arsenic acid (75-60-5)	7440-38-2	1.0
69	Cadmium & cadmium compounds	7440-43-9	1.0
70	Cobalt & Cobalt compounds	7440-48-4	1.0
71	Tris(1-chloro-2-propyl) phosphate10 (TCPP)	13674-84-5	50.0
72	Tris(1,3-dichloro-2-propyl) phosphate (TDCPP)	13674-87-8	50.0
73	Butylated hydroxyanisole (BHA)	25013-16-5	10.0
74	Nonylphenol10	25154-52-3	25.0
75	Hexabromocyclododecane	25637-99-4	50.0
76	Bis (2-ethylhexyl) tetrabromophthalate (TBPH)	26040-51-7	50.0
77	Diisodecyl phthalate (DIDP)	26761-40-0	25.0
78	Diisononyl phthalate unbranched (DINP)	28553-12-0	25.0
79	Bis(chloromethyl)propane-1,3-diyl tetrakis-(2-chloroethyl) bis(phosphate) (V6)10	38051-10-4	50.0
80	Isopropylated triphenyl phosphate10 (IPTPP)	68937-41-7	50.0
81	4-Nonylphenol branched10	84852-15-3	25.0
82	Decabromodiphenyl ethane10(DBDPE)	84852-53-9	50.0
83	Short-chain chlorinated paraffins10(SCCP)	85535-84-8	50.0
84	Chlorinated paraffins10	108171-26-2	50.0
85	2-ethylhexyl-2,3,4,5-tetrabromobenzoate10 (TBB)	183658-27-7	50.0

For more information, review what manufacturers must report (Chapter 173-334-080).

How do you submit a report?

Submit reports through the High Priority Chemical Data System (HPCDS), released by Interstate Chemical Clearinghouse (IC2).

This system allows you to file children's product reports for multiple states.
Manufacturers with large data sets can access a function set template to upload inventory to their HPCDS account.

Frequently asked questions

Companies are not required to test their products to meet the reporting requirements of the Children’s Safe Products Act (CSPA). A review of the bill of materials at component level and process knowledge may be sufficient.

We recommend to manufacturers that analyze their products:

Choose a method that states it is intended for total digestion or extraction to demonstrate total concentration as required for CSPA reporting.
Note: Methods that measure the soluble or leachable amount of a chemical do not meet CSPA reporting requirements.
Use a method approved by an authoritative agency, such as the Environmental Protection Agency (EPA).
Add certified reference material, when available, and request a case narrative of the data. This allows you to assure and assess data quality.

For further information on recommended methods for CHCC, email CSPAreporting@ecy.wa.gov.

Contact information

Susie Bautista, Children’s Safe Product Lead
cspareporting@ecy.wa.gov
360-584-3456

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