In general, all accessible components of children's products must be tested to demonstrate compliance with the lead content limit of 100 parts per million (ppm). However, there is an exemption from total lead content testing requirements for “ordinary books” and “ordinary paper-based printed materials,” as defined in Pub. Law No. 112-28.
Ordinary books are printed on paper or cardboard, printed with inks or toners, and bound and finished using a conventional method, and that is intended to be read or has educational value. This testing exemption for ordinary books does not include books with inherent play value, books designed or intended for a child 3 years of age or younger, and does not include any toy or other article that is not a book that is sold or packaged with an ordinary book.
Ordinary paper-based printed materials are printed on paper or cardboard, such as magazines, posters, greeting cards, and similar products, which are printed with inks or toners and bound and finished using a conventional method. This lead testing exemption for ordinary paper-based materials does not apply if the item is printed on material other than paper or cardboard or contains non-paper-based components such as metal or plastic parts or accessories that are not part of the binding and finishing.
Section 2 of a Children’s Product Certificate (CPC) requires a list of applicable citations for the product being certified. The citation for total lead content in substrate materials is: 15 USC § 1278a. If you are relying on this testing exemption, Section 6 of your Children’s Product Certificate (CPC) will need to reference PL 112-28 and specify that your product meets the definition of an ordinary book or ordinary paper-based printed material.