M+E Daily
Proposed Federal Rule: ‘Most’ Packaged Media Not Subject To Safety Labeling Requirements
Story Highlights
A law requiring manufacturers to label children’s products as meeting restrictions for lead and other harmful chemicals does not apply to “most” DVDs, CDs and videogames, according to a proposed rule by the federal Consumer Product Safety Commission.
However, a grey area in the rule’s definition of “children’s product” could still hold workflow implications for suppliers of plastic DVD and CD cases.
The proposed rule, published in late April (PDF here, see pages 7 and 8), aims to help manufacturers determine whether or not the government would consider a given product as primarily designed for children ages 12 and younger – and hence subject to the “children’s product” restrictions.
Regarding DVDs and other digital media, the rule notes that most titles would be deemed “general use” products, as they do not primarily appeal to children ages 12 and younger. Even titles containing programming for very young children would not have to bear the children’s product labels, since children themselves are unlikely to handle the discs or load them into players.
“However,” the rule states, “DVDs and CDs and other digital media that may be handled by older children could be considered children’s products if such movies, videogames, or music were specifically aimed at and marketed to children 12 years of age or younger and have no appeal to older audiences.”
So under certain circumstances, an Amaray case for a kids’ DVD may need to bear a label certifying that the package meets the guidelines of the Consumer Product Safety Improvement Act (CPSIA).
That means compliance is still a potential issue for package suppliers as well as disc replicators. Manufacturers effectively have two options:
•Add labels only to would-be “children’s product” packages. Though manufacturers would have to separate “children’s product” work from other jobs, this would add cost and process steps only to a limited percentage of titles. Still, an issue could someday arise of whether a given package should have been classified as a “children’s product.”
•Add labels to all packages. This would ensure 100% compliance and presumably keep the industry’s automated workflows intact — but at additional cost.
The Consumer Product Safety Commission (CPSC) is accepting comments on the proposed language through June 21. The first page of the government PDF carries instructions on comment submissions.
