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How will the lead in substrate provision be applied to products like strollers, playpens and other juvenile products? Will it be applied to every single part, including rivets?

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How will the lead in substrate provision be applied to products like strollers, playpens and other juvenile products? Will it be applied to every single part, including rivets?

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The new lead limits will apply to the total lead content by weight for any part of the product. Some childrens products or component part of products may be exempted or excluded from the new lead limits if the parts containing lead are inaccessible. Inaccessible parts do not need to meet the lead limits and the Commission will provide guidance by rule within one year on what component parts are considered inaccessible. Until that time, it is the manufacturers responsibility to determine which parts of its products are accessible and therefore must meet the statutory lead limits.

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The new lead limits will apply to the total lead content by weight for any part of the product. Some childrens products or component part of products may be exempted or excluded from the new lead limits if the parts containing lead are inaccessible. Inaccessible parts do not need to meet the lead limits and the Commission will provide guidance by rule within one year on what component parts are considered inaccessible. Until that time, it is the manufacturers responsibility to determine which parts of its products are accessible and therefore must meet the statutory lead limits.

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