The Consumer Product Safety Commission (CPSC) announced yesterday a voluntary recall of certain girl’s clothing for violation of the Consumer Product Safety Improvement Act’s (CPSIA) lead content standard. The clothing items were distributed under the name My Michelle and sold at Dillard’s, Burlington Coat Factory, Kohl’s and others. The decorative trim and attached necklaces on the clothing items have lead present above the current 300 parts per million (ppm) limit under the CPSIA.
This recall is interesting because it deals with the decorative trim items attached to clothing. Now, if you aren’t familiar with the CPSIA, let me briefly explain that the CPSIA established a lead content limit for children’s products or any part of any children’s product. The current limit is 300 ppm, and that limit is to drop to 100 ppm in August of this year unless the CPSC finds it technologically infeasible (or there is some legislative fix). Children’s products include clothing, so all parts of children’s clothing must meet the 300 ppm lead content limit.
For most fabrics, this is easy. The CPSC has deemed most textiles (undyed and dyed) to be compliant with the forthcoming 100 ppm lead content limit. So, a lot of children’s clothing manufacturers have basically starting ignoring the CPSIA since most fabrics and thread don’t need to undergo any testing to meet the lead content standard (although this ignores the other requirements, including permanent tracking labels and general textile flammability). But add bling to clothing, and you’ve got a problem. And manufacturers and importers should not forget that.
Why is this? Because a lot of bling can’t pass the lead content limits. Most true crystals – meaning glass with lead added such as the Swarovski crystals – just can’t pass. Most Swarovski crystals test at around 240,000 ppm lead. There may be no reasonable expectation of an exposure to the lead in a crystal matrix, but the CPSIA isn’t based upon exposure. No. It is based upon a limit of total lead content. So those crystals are out.
That is also true of a lot of the decorative glass beads. Those fabulous colors inside the bead often have lead in them. So they can’t be added to children’s clothing even though no risk of exposure exists.
I’ve seen a lot of children’s clothing in the marketplace recently decked out with all sorts of bling. The look of attached necklaces and other jewelry seems to be in for the tween crowd. But making sure that bling is compliant is important (even if you debate the merit of the requirement).