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Trade and Industry Department The Government of the Hong Kong Special Administrative Region
Brand Hong Kong - Asia world city
MY COLOUR

Commercial Information Circulars

24-hour hotline : 23 922 922

e-mail address : enquiry@tid.gov.hk

Ref : EIC 111/2/21

21 January 2010

Dear Sirs,

Commercial Information Circular No. 34/2010

US : Final Rule on Exemptions from Lead Limits for Certain Children's Electronic Devices

The US Consumer Product Safety Commission (CPSC) issued in the Federal Register (FR) notice of 20 January 2010 a final rule concerning certain electronic devices which are not technologically feasible to meet the lead limits as required under Section 101 of the US Consumer Product Safety Improvement Act of 2008 (CPSIA). The final rule has become effective on 20 January 2010. A copy (pdf format) of the FR notice is appended to this circular for reference.

DETAILS

  1. After 14 August 2009, products designed or intended primarily for children 12 and younger cannot contain more than 300 parts per million (ppm) of lead. The limit will be further reduced to 100 ppm after 14 August 2011, unless the CPSC determines that it is not technologically feasible to meet this lower limit. However, if the CPSC determines that it is not technologically feasible for certain electronic devices to comply with the lead limits, Section 101(b)(4) of the CPSIA provides that the CPSC shall issue requirements by regulation to eliminate or minimize the potential for exposure to and accessibility of lead in such electronic devices.

  1. The trade was informed via Commercial Information Circular No. 84/2009 that the CPSC published a notice in the FR of 12 February 2009 to seek public comments on its interim final rule on exemptions from lead limits for certain electronic devices which are not technologically feasible to meet the CPSIA lead limits. After review of comments received, it now issues the final rule.

  1. According to the final rule, the CPSC has granted exemptions for certain accessible lead-containing component parts in children's electronic devices unable to meet the lead limits set forth in Section 101 of the CPSIA due to technological infeasibility, provided that use of lead is necessary for the proper electronic functioning of the component part and it is not technologically feasible for the component part to meet the lead content limits. These exemptions include:

  1. Lead blended into the glass of cathode ray tubes, electronic components, and fluorescent tubes.

  1. Lead used as an alloying element in steel. The maximum amount of lead shall be less than 0.35% by weight (3,500 ppm).

  1. Lead used in the manufacture of aluminum. The maximum amount of lead shall be less than 0.4% by weight (4,000 ppm).

  1. Lead used in copper-based alloys. The maximum amount of lead shall be less than 4% by weight (40,000 ppm).

  1. Lead used in lead-bronze bearing shells and bushings.

  1. Lead used in compliant pin connector systems.

  1. Lead used in optical and filter glass.

  1. Lead oxide in plasma display panels and surface conduction electron emitter displays used in structural elements; notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and frit ring, as well as in print pastes.

  1. Lead oxide in the glass envelope of Black Light Blue lamps.

Components of electronic devices that are removable or replaceable, such as battery packs and light bulbs that are inaccessible when the product is assembled in functional form or are otherwise granted an exemption, are not subject to the lead limits specified in Section 101 of the CPSIA. More details of the final rule are set out in the FR notice.

ENQUIRIES

  1. Separately, the CPSC has prepared and posted to its website a brief summary and a list of frequently asked questions related to the lead limits required under the CPSIA which are available at http://www.cpsc.gov/about/cpsia/sect101.html. The CPSC has also prepared a Chinese webpage (http://www.cpsc.gov/businfo/intl/newusreq_ch.html) for
    information. Traders are strongly advised to seek clarifications with their importers in the US in order to comply with the necessary requirements.

  1. For enquiries concerning the content of this circular, please contact the undersigned at 2398 5682.

Yours faithfully,

 


(Miss Bonny CHAO)
for Director-General of Trade and Industry