The US state of Vermont’s Department of Health (DoH) has published guidance to help economic operators in the children’s product sector comply with the latest reporting requirements relating to chemicals of high concern to children (CHCC) in the Children’s Product Rule.
The guidance document – September 2020 Chemical Disclosure Guidance for Manufacturers – contains multiple changes, including:
• Clarification that the 2021 reporting period is for children’s 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 children’s 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 DoH’s 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 children’s products is January 31, 2022, and annually thereafter
3. Introduction of interim reporting by July 31 every year for children’s 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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