In This Issue:
• CPSIA 2008 affects publishers of Children’s Books
 — Introduction: New regulations on lead and Phthlates
 — Effect on Book Publishing industry
 — Managing the new rules when printing in China
• Case Study: Okidokie Sounds For Silence
• Meet the Staff: Alan Shao
• Upcoming Events: Book Expo America and others


  China Printing News, Tips on China Print Production & Case Studies

The CPSIA 2008 Imposes Limits on Lead, Phthalates in Children's Books


1. Background Introduction - New regulations for heavy metals and phthalates in Children’s products
The Consumer Product Safety Improvement Act (CPSIA) of 2008 establishes specific limits on lead in children's products. Under section 101(a) of the CPSIA, products designed or intended primarily for children 12 years of age or younger may not contain more than 600 ppm of lead by weight for any part of the product after February 10, 2009, may not contain more than 300 ppm after August 14, 2009, and 100 ppm after August 14, 2011, unless the Commission determines that it is not technologically feasible to have this lower limit.

In tandem, section 108 of the CPSIA 2008 permanently bans children's toys and child care articles containing more than 0.1% of three specific phthalates and on an interim basis bans children's toys and child care articles than can be placed in the mouth which contain more than 0.1% of 3 additional phthalates. Starting on February 10, 2009, these products can no longer be sold, offered for sale, manufactured or imported for sale to the United States unless they adhere to the new law.

The law further specifies the requirements of manufacturer certificates and 3rd party testing to demonstrate compliance.

To view the completeFederal register publication on Section 101a, click here
To view a complete CPSC advisory on Section 108 click here
To view a detailed timetable of limits and effective dates, click here
To visit the CPSC website, click here



Summary:

• Lead limits for books specifically designed for children, or with inherent play value ONLY.
• Printing Ink is not paint
• Book-Toy Combinations and Books with Play Value are subject to Section 108 restrictions

2. Effect of CPSIA 2008 on Publishing Industry
After requests for clarification from the Association of American Publishers and others, the Consumer Product Safety Commission (CPSC) issued guidance on the applicability of the CPSIA 2008 to books and similar products.

In a letter dated December 23, 2008 CPSC General Counsel Cheryl A. Falvey stated that books intended for reading by the general public (including children), by definition "are not intended or designed primarily for children. Therefore those books do not need a general conformity certification for lead content and do not require third-party testing of any kind."

While that is considered legal opinion and not an approved exemption by the Commission, it is now generally believed that books and other publication are NOT required to comply with the lead guidelines of CPSIA 2008 UNLESS they are specifically designed for children or have inherent play value.

As for Section 108 covering phthalates, the same advisory states that "ordinary books ....are reading materials and not toys and, therefore, the phthalates provisions of the CPSIA do not apply to them." It is clear then that books which DO have play-value (for instance vinyl bath books or books with removable die cut shapes),fall under the guidance of Section 108.


To read the full text of Ms. Falvey's letter: click here

Highlights of the advisory opinion on lead and phthalates in books and relevant compliance deadlines are summarized in the table below:

Book Product/ Description
Substance
Requirement
Books intended or designed primarily for children
(whether ordinary books or books with inherent play value)
Lead Content
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011)
Books intended or designed primarily for
children that have some inherent play value
or components with inherent play value
Lead Content
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011)
Phthalates
≤ 0.1% DEHP, DBP or BBP
≤ 0.1% DIDP, DINP or DNOP
(if can be placed in the mouth)
Toy (sold together with an ordinary book)
Lead Content
≤ 600 ppm (Feb 10,2009)
≤ 300 ppm (Aug 14,2009)
≤ 100 ppm (Aug 14,2011)
Phthalates
≤ 0.1% DEHP, DBP or BBP
≤ 0.1% DIDP, DINP or DNOP
(if can be placed in the mouth)

3. Managing the New Rules when Printing in China
Keeping pace with the times, China Printing Solutions International has fully studied the new CPSC regulations in order to support not only its American publishing clients, but those International publishers who may wish to sell their product in the United States. After careful consideration, CPS has established the following process to ensure compliance with CPSIA 2008 guidelines. In addition to provision of Manufacturer's Certification of general conformity, the following tests are available at this time:

I. Ordinary Children's Books:
- Final product tested only
- Test time required: Normally 5-7 days
- Charges: $20.00/element (Example: test ink, paper, board, lamination and Head/Tail bands, totally 5 elements with $100.00 charged.)
- Client will get a formal accredited 3rd party report showing the book complies with “the Lead Requirement of US Public Law 110-314 [HR 4040 ‘Consumer Product Safety Improvement Act of 2008]”

II. Children's Books with inherent play value or toy component:
- Final product tested only
- Test time required: Normally 5-7 days
- Charges: $155.00/element
- Client will get a formal accredited 3rd party report showing the book complies with “the Lead Requirement of US Public Law 110-314 [HR 4040 ‘ Consumer Product Safety Improvement Act of 2008]” and “the Phthalate Requirement of US Public Law 110-314 [HR 4040 ‘Consumer Product Safety Improvement Act of 2008]”

Fees and lead time are subject to change.
If you have any questions about this procedure, or wish to discuss further, please email us at: info(at)chinaprintingsolutions.com


Case Study:
Okidokie Sounds For Silence

Client: Okiedokie Pty Ltd. (Australia)

Project Name: Sounds for Silence

Description:
Sounds for Silence is a CD of sounds specially designed by an Australian pediatrician which has been proven to aid in helping babies sleep. Previously sold in a PVC pouch, the product needed an upgrade in accordance with the company’s interest to sell it internationally. CPS designed a hardback CD sleeve and cloth covered slipcase to hold the product components in a classy, high value product. A big success, the initial print run of a few thousand pieces was quadrupled in the second order.

For More Case Studies, Please Click Here

Meet the Staff:
Alan Shao I Production Manager


Hailing from AnHui, a province neighboring Shanghai, Alan Shao holds both an Undergraduate and a Master’s degree in printing technology. In the 10 years course of his career he has worked in a variety of roles in offset printing, including jobs as a Press operator, as a materials purchaser and in sales.

In his current role for CPS as Production Manager, Alan supervises a team undertaking new estimates, material and machine specifications, quality assurance and scheduling. Drawing on a deep understanding of the printing process and a wide network of supply contacts throughout China, Alan routinely proposes process improvements that increase quality and reduce cost.

Cheerful and optimistic by nature, Alan is a former University league Soccer star, and still enjoys a good match on his days off, away from the buzz of printing machinery.
Alan can be reached at ashao(at)chinaprintingsolutions.com.

Upcoming Events
May, 2009

Canton Fair
Phase 1: April 15th – 19th, 2009
Phase 2: April 24th – 28th, 2009
Phase 3: May 3rd – 7th, 2009
For more information please click
www.cantonfair.org.cn

April 27-30 Hong Kong Int'l Printing and Packaging Fair
For more information please click
http://www.hkprintpackfair.com/

May 12-16: 7th Beijing International Printing Technology Exhibition
For more information please click
http://www.chinaprint.com.cn/index.jsp?intEn=1

May 28-31: BookExpo America, New York

CPS will exhibit in BEA 2009 at booth No. 3929
CPS Founder and General Manager Aaron Brent Landiswill be on hand to meet with you at our booth. alandis(at)chinaprintingsolutions.com
For more information please click
www.bookexpoamerica.com/en/


IN THE NEXT ISSUE:
GREEN PRINTING AND PACKAGING IN CHINA!

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