MJSA is pretty deeply immersed in the lead issue. We followed the
Consumer Product Safety Improvement Act through Congress, providing
to members along the way through MJSA Journal and other
media. Now we have association staff and members, including a
metallurgist, working to persuade the Consumer Product Safety
Commission to write reasonable implementation rules. These rules are
crucial for anyone affected by the new standards for lead. Though the
act specifically governs only children’s products, its effects could
Some of the issues to be decided include:
Exempted materials. The act subjects crystal and precious metals
to the same testing, labeling, and other requirements as the cheapest
costume jewelry from China. However, it also gives the CPSC power to
exempt materials. We are working to persuade the commission that
precious metal jewelry, which never contains more than trace elements
of lead, should be exempted. Our ally in this effort, the Fashion
Jewelry Trade Association (FJTA), is working for a lead crystal
exemption, based on the inaccessibility of the lead.
What’s a child’s product? The act defines a child as 12 and
under, but its definition of a child’s product is subject to
interpretation. One part of it (and I’m paraphrasing) refers to a
product that would be commonly accepted as for a child. Our fear is
that creates a huge gray area of costume and precious metal jewelry
that may not be intended for children, but commonly ends up around
the necks or hanging from the ears of 10-year-old girls anyway.
How onerous will the labeling and certification requirements be
in practice? There is potential for standards that will have
manufacturers jumping through costly and unnecessary hoops.
I believe the CPSC will eventually hold hearings on these issues.
You might consider contacting the FJTA (it’s on the Web) to see what
it has and whether you can help. I don’t know offhand the
next deadline for comments, but I believe there may be further
opportunities to tell the CPSC your opinion. The commission takes
into account how its rules will affect businesses. The more
businesspeople they hear from, the more likely they are to be
persuaded to exempt crystal and precious metals.
A copy of the act is available online, as are several summaries.
Just search for CPSIA.
I hope this is helpful.