The US state of Vermonts Department of Health (DoH) has published guidance to help economic operators in the childrens product sector comply with the latest reporting requirements relating to chemicals of high concern to children (CHCC) in the Childrens Product Rule.
The guidance document September 2020 Chemical Disclosure Guidance for Manufacturers contains multiple changes, including:
Clarification that the 2021 reporting period is for childrens products offered for sale or distribution in the state between September 1, 2020 and January 31, 2022, and reporting will continue annually thereafter
Indication that manufacturers should report the anticipated concentration of formaldehyde for products containing the listed formaldehyde donors. This can 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
The document also contains the dates for the 2021-2030 reporting period:
2021 September 1, 2020 to January 31, 2022
2022 February 1, 2022 to January 31, 2023
2023 February 1, 2023 to January 31, 2024
2024 February 1, 2024 to January 31, 2025
2025 February 1, 2025 to January 31, 2026
2026 February 1, 2026 to January 31, 2027
2027 February 1, 2027 to January 31, 2028
2028 February 1, 2028 to January 31, 2029
2029 February 1, 2029 to January 31, 2030
2030 February 1, 2030 to January 31, 2031
Stakeholders should note July 31 is the interim reporting deadline for childrens products that are offered for sale after the start of each reporting period. Products reported by this date are not then required to be re-reported in the same reporting period.
The guidance relates to the Vermont DoHs most recent revision, which came into effect on September 1, 2020. It contains three important changes:
1. Inclusion of formaldehyde donors as part of its requirements for formaldehyde
2. Clarification that the next reporting date for childrens products is January 31, 2022, and annually thereafter
3. Introduction of interim reporting by July 31 every year for childrens products that are offered for sale or distributed in the state between January 31 and July 31 of that year
SGS Toy & Juvenile Product Services
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