Vermont has published a draft rule to expand the definition of formaldehyde under its disclosure program for children’s products. Comments are accepted until December 11, 2019.

SAFEGUARDS | Consumer ProductsNO. 172/19


The US state of Vermont disclosure program for children’s products (V.S.A. Title 18: Chapter 38A ‘Chemicals of High Concern to Children’ (the ‘Act’)) requires 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).

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

On October 30, 2019, the DOH posted a proposal 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 (SafeGuardS 160/19).

The DOH has posted the proposed rule to amend the Act. The proposed two changes are:

  1. Expanding the definition of formaldehyde – from ‘Formaldehyde’ to ‘Formaldehyde and substances that are intentionally added to release formaldehyde, including but not limited to, DMDM hydantoin (also known as 1,3-bis(hydroxymethyl)-5,5-dimethylimidazolidine-2,4-dione), imidazolidinyl urea, diazolidinyl urea, and quaternium-15’
  2. Clarifying that reporting will be required within 30 days from the time the product is offered for sale or distributed after August 31, 2020 and such reporting will continue on an annual basis

According to DOH website, comments are accepted until December 11, 2019.

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