US State of Washington Expands CHCC Reporting List
SAFEGUARDS | Consumer Products NO. 157/17
In 2008, Washington State enacted the Children’s Safe Products Act (CSPA). As part of that law, codified as Chapter 173-334 WAC [1], the state’s Department of Ecology (DOE) established 66 Chemicals of High Concern to Children (CHCCs) and required manufacturers to annually report if children’s products contained these chemicals that are intentionally added and exceeds the practical quantitation limit (PQL) or more than 100 ppm as a contaminant.
In 2013, DOE delisted [2] 1-butanol (CAS 71-36-3) and added tris-(1-chloro-2-propyl) phosphate (TCPP, CAS 13674-84-5) to the list of CHCCs.
On September 29, 2017 [3], DOE adopted an amendment to the CPSA Reporting Rule [4]. This amendment contains a number of important changes, including:
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Adding 20 new chemicals to the CHCC list (see Table 1 for these 20 new chemicals). These are mainly flame retardants, phthalates and two BPA analogues (BPS and BPF)
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Separating 4-nonylphenol (NP) and its 2 isomeric forms from one entry into 3 separate entries
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Deleting 3 chemicals from the CHCC list. These are phthalic anhydride, octamethylcyclotetrasiloxane (D4) and molybdenum and its compounds (Mo)
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Reports due on January 31, 2019, applies to children’s products for the period September 1, 2017 to December 31, 2018. Manufacturers may request an extension to this reporting deadline provided this is their first report and reporting is for more than one chemical or product.
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Reports due on January 31, 2020, and annually thereafter, are for children’s products from the prior calendar year.
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Reporting parties must copy the report from the previous year and report the same data into the online reporting database if there are no changes since the previous annual report.
The new CSPA Reporting Rule contains 85 CHCCs and will become effective on October 30, 2017 [5].
Details of the 20 newly added CHCCs are summarized in the Table below.
| Entry | Name | Abbreviation or Acronym | CAS |
|---|---|---|---|
| 1 | 2-Ethylhexyl-2,3,4,5-tetrabromobenzoate | TBB | 183658-27-7 |
| 2 | Bis(chloromethyl)propane-1,3-diyl tetrakis-(2-chloroethyl) bis(phosphate) | V6 | 38051-10-4 |
| 3 | Bis (2-ethylhexyl) tetrabromophthalate | TBPH | 26040-51-7 |
| 4 | Bisphenol F | BPF | 620-92-8 |
| 5 | Bisphenol S | BPS | 80-09-1 |
| 6 | Chlorinated paraffins | -- | 108171-26-2 |
| 7 | Decabromodiphenyl ethane | DBDPE | 84852-53-9 |
| 8 | Di-(2-methoxyethyl) phthalate | DMEP | 117-82-8 |
| 9 | Dicyclohexyl phthalate | DCHP | 84-61-7 |
| 10 | Diisobutyl phthalate | DIBP | 84-69-5 |
| 11 | Dipentyl phthalate | DPP | 131-18-0 |
| 12 | Ethylhexyl diphenyl phosphate | EHDPP | 1241-94-7 |
| 13 | Isopropylated triphenyl phosphate | IPTPP | 68937-41-7 |
| 14 | Perfluorooctanoic acid and related substances | PFOA | 335-67-1 |
| 15 | Short-chain chlorinated paraffins | SCCP | 85535-84-8 |
| 16 | Tricresyl phosphate | TCP | 1330-78-5 |
| 17 | Tri-n-butyl phosphate | TNBP | 126-73-8 |
| 18 | Triphenyl phosphate | TPP | 115-86-6 |
| 19 | Tris (1-chloro-2-propyl) phosphate | TCPP | 13674-84-5 |
| 20 | Tris (2,3-dibromopropyl) phosphate | TDBPP | 126-72-7 |
Throughout our global network of laboratories, we are able to provide a range of services, including analytical testing and consultancy, for consumer products for compliance with CSPA, Prop 65 and worldwide requirements. Please do not hesitate to contact us for further information.
Next step:
Stakeholders are advised to comply with the latest requirements for CHCCs in children’s products for the Washington State market.
For enquiries, please contact:
Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420
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