Does packaging have to comply with the lead requirements? Does it matter if the packaging is intended to be reused (e.g., heavy gauge reusable bag with zipper closure to store a set of blocks)?
CPSIA defines childrens products as those products intended primarily for use by children 12 and under. Packaging is generally not intended for use by children, given that most packaging is discarded and is not used or played with as a childrens product. However, if the packaging is intended to be reused, or used in conjunction with the childrens product, such as a heavy gauge reusable bag used to hold blocks, it becomes a component or part of the product, and would be subject to the lead requirements of CPSIA. It should also be noted that many individual states have adopted packaging laws which address toxics in packaging or packaging components and which have not been preempted by Commission action.
CPSIA defines childrens products as those products intended primarily for use by children 12 and under. Packaging is generally not intended for use by children, given that most packaging is discarded and is not used or played with as a childrens product. However, if the packaging is intended to be reused, or used in conjunction with the childrens product, such as a heavy gauge reusable bag used to hold blocks, it becomes a component or part of the product, and would be subject to the lead requirements of CPSIA. It should also be noted that many individual states have adopted packaging laws which address toxics in packaging or packaging components and which have not been preempted by Commission action.
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