Vermont, USA, Publishes Guidance for CHCC in Children’s Products Rule
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
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):
- Inclusion of formaldehyde donors as part of its requirements for formaldehyde
- Clarification that the next reporting date for children’s products is January 31, 2022, and annually thereafter
- 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
||February 1, 2022
||January 31, 2023
||February 1, 2023
||January 31, 2024
||February 1, 2024
||January 31, 2025
||February 1, 2025||January 31, 2026
||February 1, 2026
||January 31, 2027
||February 1, 2027
||January 31, 2028
||February 1, 2028||January 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.
- 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
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