Children's Safe Products Act reporting

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).

Read our Children's Safe Products Reporting Rule: Product Components publication for more information.

​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

A list of chemical functions is available to select when you file your report in HPCDS.

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.

Product testing studies

We monitor the market by conducting product testing studies. We have initiated over 20 product testing studies on products such as children’s clothing, jewelry, cosmetics, toys, bottles, bedding, furniture, and more. As a result of our product testing efforts, we have issued over 150 compliance letters to manufacturers.

Study development

We develop studies that focus on priority toxic chemicals, popular products, underrepresented or more susceptible populations, and manufacturers with previous violations. Some of our studies include the following:

• Flame Retardants in children’s Tents, Ply Tunnels and Upholstered Chairs.
• Formaldehyde, D4, MEK, and Styrene in Children’s Products.
• Chemicals of High Concern to Children in Children’s Clothing, Footwear, and Accessories 2018.
• Cadmium and Other Metals in Children’s Jewelry 2018, follow up study.
• Assessment of Toxic Chemicals in Children’s Products, 2019.

Enforcement actions

Most enforcement actions have specific deadlines that manufacturers need to respond by. Failure to respond by the deadline reduces the opportunity to contest the enforcement action. 

• RCW 70A.430.070 clarifies our enforcement process for manufacturers of restricted products, including penalties and required recall actions.
• WAC 173-334-120 clarifies our enforcement process for manufacturers that fail to comply with reporting requirements.

Additionally, we review all submitted reports before publishing and send inquiries to manufacturers if:

• A report is missing required information.
• A report is submitted past the deadline.
• A report includes a restricted CHCC over limits.
• A report is a duplicate or an overreport.
• We receive complaints.

Reported information helps fill a data gap that exists for both consumers and agencies. The presence of a CHCC in a children's product does not necessarily mean that the product is harmful to human health or that there is any violation of existing safety standards or laws.

Reported data is available on HPCDS.