Vermont, USA, Issues Latest CHCC in Children’s Products Rule

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

The Vermont Department of Health (DOH) has recently made available the latest CHCC in Children’s Products Rule.  This version contains several important changes when compared to its previous edition. It:

• Expands the definition of formaldehyde – from ‘formaldehyde’ to ‘formaldehyde and substances that are intentionally added to release formaldehyde, including: 
  • 5-Bromo-5-nitro1,3-dioxane
  • Bronopol
  • Diazolidinyl urea
  • DMDM hydantoin – also known as 1,3-bis(hydroxymethyl)-5,5-dimethylimidazolidine-2,4-dione
  • Imidazolidinyl urea
  • Methanol, (phenylmethoxy)
  • Methenamine
  • Quaternium-15
  • Sodium N-(hydroxymethyl) glycinate
• Clarifies that a manufacturer of a children’s product offered for sale or distribution in the state should submit the required notice to the DOH on or before January 31, 2022, and annually thereafter
• Adds a new section 9 ‘Reporting between Annual Reporting Periods’ which stipulates that on or before July 31 of every year, a manufacturer of a children’s product should report all products introduced for sale or distribution in the state between January 31 and July 31 of that year

This latest edition became effective on September 1, 2020.

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