SAFEGUARDS SGS CONSUMER TESTING SERVICES

HARDLINES NO. 048/08 JUNE 2008

US Massachusetts Published Guidance for Lead in Children’s Jewelry The US State of Massachusetts has recently published a guidance document for demonstrating compliance with lead requirements for children’s jewelry. The guidance provides detailed description of jewelry products and testing methodologies for determination of lead in jewelry to facilitate industry compliance. The effective date for regulation is postponed from June 2008 to October 2008.

In March 2008, Massachusetts Table 1. Lead requirements and methods for children’s for Massachusetts adopted regulation to ban children’s jewelry containing either excessive New lead content or excessive 1 Substance Product Method Requirement Effective accessible lead . In June 2008, the date² guidance document for demonstrating compliance was officially published. In this Total Jewelry for US CPSC method for ≤ 600 ppm children lead analysis of document a number of Lead under 14 jewelry, terminologies and technicalities

have been defined including EPA 3050B and EPA ‘jewelry’ and ‘methods for total lead 3051 content and accessible lead’ (acid extraction test). Under 105 CMR or 650.000 Hazardous Substance Regulation, children’s leaded Similar method October 17, subject to approval of 2008 jewelry means jewelry marketed to MDPH or intended for use by children under 14 years of age that contains Accessible US CPSC SOP for ≤ 15 µg / day a concentration of lead that either is Lead determining lead (Pb) more than 600 ppm total lead and its Availability in content or would expose a child to Children’s Metal greater than 15 µg of accessible Jewelry lead per day (Table 1).

1. Safeguards 27/08 April 2008 ‘The Commonwealth of Massachusetts Bans Lead in Children’s Jewelry’ 2. Previous effective date was June 13, 2008 HARDLINES NO. 048/08 JUNE 2008 P.2

Jewelry Exemption

Items include but not limited to: • Karat Gold • Anklet • Sterling • Arm Cuff • Platinum • Bracelet • Palladium • Brooch • Iridium • Chain • Osmium • Crown • Ruthenium • Cuff Link • Rhodium • Decorated hair accessories • materials Compliance • Earring • Components that are • A sufficient number of • physically inaccessible, such samples from each lot, but no • Pin as interior components of a less than 0.5 % of the total • Ring number of items in each lot, • Jewelry for sale to • Body piercing jewelry must be tested to guarantee adolescents and adults 14 • Any bead, chain, link, pendant compliance with the total lead or other component of jewelry years of age and over eg content and acid extraction items for adults standards

Labeling for non-children’s jewelry Throughout our global network of laboratories, we are able to provide • Retailers may find it convenient to label jewelry intended to persons 14 a range of services, including years of age and older by adding a label to the packaging or cardboard analytical testing and consultancy backing with an alert such as the following: ‘This item may contain lead, for total lead, accessible (soluble) and is not intended for sale to or use by person 13 years of age and under’ lead and other in a Non-Compliance Jewelry Product comprehensive range of jewelry • Disposal subject to the Massachusetts Department of Environmental Pro- and other consumer products for tection’s Hazardous Waste Regulation (310 CMR 30.000) worldwide markets. Please do not hesitate to contact us for further Violation information. • First offense – not less than USD 100 nor more than USD 500 or up to 90 days imprisonment, or both • Second and subsequent offense – not less than USD 600 nor more than USD 3, 000 or up to 1 year imprisonment, or both • Product embargo

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