What are you looking for?

Vermont, USA, Publishes Guidance for CHCC in Children’s Products Rule

SafeGuardSToys and Juvenile Products, Hardgoods, Hardgoods, Softlines, SoftlinesSeptember 23, 2020

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.

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 DateEnd Date
2021September 1, 2020January 31, 2022
February 1, 2022
January 31, 2023
February 1, 2023
January 31, 2024
February 1, 2024
January 31, 2025
February 1, 2025January 31, 2026
February 1, 2026
January 31, 2027
February 1, 2027
January 31, 2028
February 1, 2028January 31, 2029
February 1, 2029
January 31, 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 

© SGS Group Management SA - 2020 - All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.

Stay on top of regulatory changes within your industry
Read more articles for the Consumer Goods and Retail industry

News & Insights

  • SGS Headquarters

1 Place des Alpes,

P.O. Box 2152, 1211,

Geneva, Switzerland