New Zealand Consults Over Proposed Revisions to Lead Requirements for Paints and Graphic Materials

SafeGuardSToys and Juvenile ProductsNovember 20, 2023

SG 155/23

New Zealand’s EPA has initiated a consultation over its proposal to amend several group standards on lead requirements for paints and graphic materials. Comments are accepted until January 26, 2024.

In October 2023, the New Zealand Environmental Protection Authority (EPA) announced proposed changes to reduce the risks from lead in corrosion inhibitors and graphic materials such as crayons, finger paints and felt-tip pens that are used by children.

The proposal seeks to revise several group standards:

Six aerosol group standards
Six corrosion inhibitor group standards
One graphic materials group standard
24 surface coatings and colorants group standards

Highlights of the proposed changes are summarized in Table 1

Proposal Number	Highlights of proposed changes
1 ‘Lead limit in paints covered by the Surface Coatings and Colorants Group Standards and Aerosols Group Standards to 90 ppm	≤ 90 ppm total lead in paints covered by the surface coatings and colorants group standards and the aerosol group standards
2 ‘Add lead limits to the Corrosion Inhibitors Group Standards’	Amends corrosion inhibitors group standards by including total lead limits as in Proposal 1 above Ensures anti-corrosive paints using the corrosion inhibitor group standards have the same lead limits as paints
3 ‘Require evidence of compliance with lead levels where relevant’	Only requires testing by an accredited laboratory for the first production batch or when chemicals or source of chemicals change
4 ‘Update element migration limits in graphic materials’	Revises migration limits for toxic elements in the graphic materials group standard so that they are consistent with AS/NZS ISO 8124.3:2021
5 ‘Update references to the AS/NZS ISO 8124.3:2003 standard	Updates AS/NZS ISO 8124.3:2003 in the surface coatings and colorants, aerosols and graphic materials group standards to the 2021 version
6 ‘Amend group standards so all graphic materials marketed to children are only covered by the Graphic Materials Group Standard’	Expands the scope of excluded graphic materials marketed for children’s use from finger paints, children’s crayons and children’s watercolor paints in the surface coatings and colorants group standards to all graphic materials marketed to children Introduces a definition of child or children as persons seven years or under Amends the graphic materials group standard to clarify that it is the only means of compliance for all graphic materials marketed to children
7 ‘Remove the notification requirement from the Graphic Materials Group Standard’	Deletes provision requiring manufacturers and importers of children’s graphic materials (water color paints, crayons and/or finger paints) falling under the graphic materials group standard to notify the EPA of leachable element testing results
8 ‘Commencement’	Applies from six months after revised group standards are notified in the gazette
9 ‘Disposal’	Stock of ‘in scope’ products that do not meet the revised group standards must be disposed of six months after commencement

Table 1

Comments will be accepted until January 26, 2024

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