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IPC Comments on Electronic Devices
Nov 13, 2008
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IPC — Association Connecting Electronics Industries, in conjunction with the Information Technology Industry Council (ITI) and the Consumer Electronics Association (CEA), provided comments to the Consumer Product Safety Commission (CPSC) on the recently enacted Consumer Product Safety Improvement Act (CPSIA).

The regulations enacted Aug. 14, 2008, include new requirements limiting the use of phthalates and lead in products intended for children. The new CPSIA regulations also require manufacturers to certify compliance with every consumer product shipment beginning Nov. 12, 2008. The CPSIA affects more than 15,000 consumer products used in and around the home, and in sports, recreation, and schools.

In its response to the CPSC, IPC noted that most electronic devices should not be considered children’s products. While some computers and other electronics are specifically designed for use by children, the majority of electronic products, such as servers, laptop computers, desktop computers and mobile internet devices, are not generally viewed as “children’s products,” even though they may be used by children from time to time under the supervision of adults.

Additionally, IPC commented that any lead used in an electronics device is inaccessible to children by any reasonably foreseeable use and abuse; that the lead limit for accessible component parts for electronic products designed and intended primarily for children under 12 be set at 1000 parts per million (ppm), in compliance with the European Union’s RoHS Directive; and that the new reporting rules be simplified.

Most electronics products are not intended for children. However, there are some electronics products that are marketed to children or that a child may misconstrue as a toy. Because the new CPSIA regulations require manufacturers to certify compliance with every consumer product regulation, manufacturers should review all pertinent regulations, not just the new lead and phthalate regulations for children’s products. Information on the CPSC and CPSIA is available at http://www.cpsc.gov/about/cpsia/cpsia.html. IPC’s comments to the CPSC can be viewed at www.ipc.org/current-GR-issues.

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