The three limits

The 100 ppm total lead limit

Updated October 2026

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The steps, as enacted And the statute points downward Any part of the product Accessible is the usual next question Where the evidence comes from And none of this applies to the component business References

The limit is total lead content by weight, for any part of the product.

The steps, as enacted

The limit referred to in the statute began at 600 parts per million total lead content by weight for any part of the product. Beginning one year after 14 August 2008 it became 300 ppm. Beginning three years after that date, 300 ppm is read as 100 ppm, unless the Commission determines that 100 ppm is not technologically feasible for a product or product category, which it may do only after notice and a hearing.

And the statute points downward

The Commission is directed to periodically review and revise the limit downward based on the best available scientific and technical information. This is not a limit to treat as a permanent number; it is a floor that the statute contemplates moving.

Any part of the product

That phrase is why findings are harder than they look. A plated ear wire is a base metal, a plating layer and sometimes a solder joint. Each is a part. A lead content figure for the finished weight of the piece is not the same measurement as a figure for the part that fails.

Accessible is the usual next question

The Commission’s rules on inaccessible component parts are the place to answer whether a given part is treated as accessible, and the answer depends on the construction of the article. A finding is, by its nature, exposed, so most of this discussion resolves against you here.

Where the evidence comes from

From testing, in the end. A supplier statement is useful for narrowing a search and useless as a certificate. If you are in the children’s regime you are going to accredited third party testing anyway, and the sensible order is to screen candidate parts before committing to one.

And none of this applies to the component business

If the pack is not a children’s product, this section is not your obligation. Saying so plainly matters as much as stating the limit, because a supplier who implies the limit applies to everything is selling testing, not accuracy.

References

15 U.S.C. 1278a, Children’s products containing lead; lead paint rule. Total lead content by weight for any part of the product: 600 ppm, then 300 ppm one year after 14 August 2008, then 100 ppm three years after, unless the Commission determines 100 ppm is not technologically feasible for a product or category. The Commission is to review and revise the limit downward periodically. law.cornell.edu

15 U.S.C. 2052(a)(2), the Consumer Product Safety Act definitions as amended by the CPSIA. A children’s product is a consumer product designed or intended primarily for children 12 years of age or younger, determined by four factors: a manufacturer statement including a label if reasonable; representation in packaging, display, promotion or advertising; common recognition by consumers; and the Commission staff’s September 2002 Age Determination Guidelines. law.cornell.edu

Written from the CPSIA and the CPSC regulations, not from a bench. Whether a particular product is a children’s product is a determination on the facts of that product, and state law in this area has not been surveyed here. Nothing on these pages is advice on a specific item.