Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

CPSIA Updated re Lead in Electronic Products

The Consumer Product Safety Commission has amended the CPSIA by exempting electronic products from the lead limitation provided by Section 101(b)(2) provided the component part is not accessible "if it is not physically exposed by reason of a sealed covering or casing and does not become physically exposed through reasonably foreseeable use and abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product, as determined by the Commission." Non functional uses of lead remain subject to Section 101. Paint, coatings and electroplating are not a barrier to access by a child. However, there is also an exemption granted to certain accessible lead-containing component parts which are accessible due to it not being technologically feasible to reduce their lead content. These are other changes were published in the Federal Register on January 20, 2010, see

The CPSC also issued mandatory recall final regulations in the January 21, 2010 Federal Register. See for more details. for the full text.

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