Vermont has recently proposed a revision to its disclosure program for children’s products by expanding the definition of formaldehyde. Comments are accepted until December 11, 2019.

SAFEGUARDS | Consumer ProductsNO. 160/19


In June 2014, the US state of Vermont signed the S.238 bill into law (Act 188 codified as V.S.A. Title 18: Chapter 38A ‘Chemicals of High Concern to Children’) (the ‘Act’) to require a manufacturer of a children’s product or a trade association representing a manufacturer of children’s products to report the presence of chemicals of high concern to children (CHCCs) to the Department of Health (DOH) (SafeGuardS 121/14). That piece of legislation also directs the DOH to publish ‘Rules’ for implementing the Act.

According to the Act, reporting is required if the CHCC is in an accessible component of a children’s product, and is:

  • Intentionally added and is greater than the practical quantification limit (PQL), or
  • A contaminant that is equal to or greater than 100 ppm

The CHCC reporting rule, as amended, contains 86 entries on the CHCC list and has revised the reporting frequency from biennially to annually for submissions after August 31, 2020 (SafeGuardS 118/19)

On October 30, 2019, the DOH posted a proposal (Number 19PO74) to expand the definition of formaldehyde to include ‘formaldehyde donors’ – substances that are intentionally added to a product to degrade to and release formaldehyde as a preservative.

According to the proposal, comments are accepted until December 11, 2019

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