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The US state of Vermont has recently published its latest chemical disclosure guidance for manufacturers which details the reporting dates and clarifies how formaldehyde donor concentrations are to be reported.

SAFEGUARDS | Consumer ProductsNO. 144/20

 SG 14420 Balls

In its most recent revision, September 2020, the Vermont Department of Health (DOH) published an amendment to the Chemicals of High Concern to Children (CHCC) in Children’s Products Rule (V.S.A Title 18: Chapter 38A ‘Chemicals of High Concern to Children’.

The amendment, which became effective on September 1, 2020, contains three important changes (SafeGuardS 135/20):


  1. Inclusion of formaldehyde donors as part of its requirements for formaldehyde
  2. Clarification that the next reporting date for children’s products is January 31, 2022, and annually thereafter
  3. Introduction of interim reporting by July 31 every year for children’s products that are offered for sale or distributed in the state between January 31 and July 31 of that year 

The Vermont DOH also issued its September 2020 Chemical Disclosure Guidance for Manufacturers to assist economic operators of children’s products to comply with the latest reporting requirements. The latest guideline contains several major changes when compared to its previous version. It:

  • Clarifies that the 2021 reporting period is for children’s products offered for sale or distribution in the state between September 1, 2020 and January 31, 2022, and reporting will continue annually thereafter
  • Details the dates for the 2021-2030 reporting period (see Table 1 below)
Reporting Year* Start Date End Date
2021 September 1, 2020 January 31, 2022
2022
February 1, 2022
January 31, 2023
2023
February 1, 2023
January 31, 2024
2024
February 1, 2024
January 31, 2025
2025
February 1, 2025 January 31, 2026
2026
February 1, 2026
January 31, 2027
2027
February 1, 2027
January 31, 2028
2028
February 1, 2028 January 31, 2029
2029
February 1, 2029
January 31, 2030
2030
February 1, 2030
January 31, 2031
*July 31 is the interim reporting deadline for children’s products that are offered for sale after the start of each reporting period. Products reported by this date are not required to be re-reported in the same reporting period. 

Table 1

  • Indicates that manufacturers should report the anticipated concentration of formaldehyde for products containing the listed formaldehyde donors. This may be obtained by testing the product, or by working within the supply chain to understand what concentration of formaldehyde is expected to be released from a specific donor

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides 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. Please do not hesitate to contact us for further information.

Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420

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