SG 101/26
US state of Vermont issues revised guidance for reporting children’s products containing chemicals of high concern to children (CHCCs).
Vermont’s disclosure program for children’s products (V.S.A. Title 18: Chapter 38A ‘Chemicals of High Concern for Children (the Act)) requires manufacturers of children’s products, or trade associations representing such manufacturers, to report the presence of (CHCCs) to the Department of Health (DoH).
The term ‘children’s product’ means any consumer product intended for or marketed to children under 12 years of age, including toys, children’s cosmetics and jewelry, teething and feeding products, children’s clothing and child car seats.
According to the Act, reporting is required if the CHCC is in an accessible component of a children’s product and is either:
- Intentionally added at a concentration greater than the practical quantification limit (PQL)
- Present as a contaminant at a concentration equal to or greater than 100 ppm
Vermont’s DOH has recently issued its June 2026 Chemical Disclosure Guidance for Manufacturers to assist economic operators of children's products to comply with the reporting requirements.
What does this guideline require?
Key changes introduced in the June 2026 guidance include:
- Updating the decision flowchart with step-by-step guidance for determining whether a chemical is subject to reporting requirements
- Clarifying that only one entity is required to submit a report for a specific children’s product using the updated High Priority Chemicals Database (HPCDS) reporting guide
- Clarifying how formaldehyde donor concentrations are reported, with DMDM hydantoin (CAS 6440-58-0) as an example
Similar to the 2024 guidance, the latest guidance details the dates for the 2025-2030 reporting period (see Table1 below).
| Date product is introduced¹ | Report by date² | Fee period³ | Reporting period⁴ |
| 2/1/2025 - 7/31/2025 | 7/31/2025 | 2/1/2025 - 1/31/2026 | 2025 |
| 8/1/2025 - 1/31/2026 | 1/31/2026 | 2/1/2025 - 1/31/2026 | 2025 |
| 2/1/2026 - 7/31/2026 | 7/31/2026 | 2/1/2026 - 1/31/2027 | 2026 |
| 8/1/2026 - 1/31/2027 | 1/31/2027 | 2/1/2026 - 1/31/2027 | 2026 |
| 2/1/2027 - 7/31/2027 | 7/31/2027 | 2/1/2027 - 1/31/2028 | 2027 |
| 8/1/2027 - 1/31/2028 | 1/31/2028 | 2/1/2027 - 1/31/2028 | 2027 |
| 2/1/2028 - 7/31/2028 | 7/31/2028 | 2/1/2028 - 1/31/2029 | 2028 |
| 8/1/2028 - 1/31/2029 | 1/31/2029 | 2/1/2028 - 1/31/2029 | 2028 |
| 2/1/2029 - 7/31/2029 | 7/31/2029 | 2/1/2029 - 1/31/2030 | 2029 |
| 8/1/2029 - 1/31/2030 | 1/31/2030 | 2/1/2029 - 1/31/2030 | 2029 |
| 2/1/2030 - 7/31/2030 | 7/31/2030 | 2/1/2030 - 1/31/2031 | 2030 |
| 8/1/2030 - 1/31/2031 | 1/31/2031 | 2/1/2030 - 1/31/2031 | 2030 |
| ¹Date product introduced – the date on which the product is first offered for sale or distribution in the state during the reporting period. This date determines whether the product must be reported by July 31 or January 31 of the applicable reporting and fee period ²Report by date – the date by which reports must be submitted for products offered for sale or distribution in Vermont to children during the fee period ³Fee period – the reporting period between the designated start and end dates. A fee of USD 200 per chemical is charged upon submission of the first report for that chemical during the fee period. Chemicals must be reported during the fee periods in which the product is offered for sale in Vermont ⁴Reporting period – the year the fee period begins. The reporting system permits reporting only for the current period | |||
Table 1
Who is impacted?
The guidance affects stakeholders across the children’s products supply chain, including manufacturers, importers, sellers, distributors and other intermediaries operating in the Vermont market.
We are committed to providing information about regulatory developments for consumer products as a complimentary service. Through our global network of experts and laboratories, we provide a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.
© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.
