Does packaging have to comply with the lead requirements?
A. CPSIA defines children’s products as those products intended primarily for use by children aged 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 children’s product. However, if the packaging is intended to be reused, or used in conjunction with the children’s product, such as a 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 U.S. States have adopted packaging laws which address toxics in packaging or packaging components and which have not been preempted by Commission action.
