Consumer Promotional Products Safety

Promotional Products Safety

Age Grading

Method of ensuring that products are appropriate and safe for particular stages of a child’s development. Age grading should determine the physical and mental ability needed in order to play with and understand a product.

American Society for Testing and Materials (ASTM)

Founded in 1898, one of the oldest standards developing organizations is a globally recognized leader in the development and delivery of international voluntary consensus standards. Today, some 12,000 ASTM standards are used around the world to improve product quality, enhance safety, facilitate market access and trade, and build consumer confidence.


See American Society for Testing and Materials (ASTM). Bisphenol A (BPA) A chemical used primarily in polycarbonate material as well as epoxy resins and polysulfone materials. The Food and Drug Administration (FDA) has issued regulations that prohibit the use of BPA in baby bottles and caps. Some states are pursuing bans of BPA in general-use food containers, water bottles and the linings of metal cans.


See Bisphenol A.


A metal found in toys and in children’s jewelry. New regulations regarding cadmium are expected to be enacted soon. Some states have already passed laws regarding the use of cadmium, primarily in children’s jewelry. European standards limit total cadmium to 100 ppm.

California Proposition 65

Also known as the Safe Drinking Water and Toxic Enforcement Act of 1986, California Proposition 65 is a law that requires businesses to notify Californians about significant amounts of chemicals in the products they purchase, in homes or workplaces, or that are released into the environment. Businesses are required to provide a “clear and reasonable” warning before knowingly and intentionally exposing anyone to a listed chemical.

Canada Consumer Product Safety Act (CCPSA)

A Canadian law to protect consumers by addressing or preventing exposure to dangerous consumer products. The CCPSA applies to a wide variety of consumer products including children’s toys, household products and sporting goods. Key provisions of the CCPSA include incident reporting, document maintenance, general prohibitions and packaging and labeling requirements. Obligations exist for those who manufacture, import, sell or advertise consumer products in Canada. CCPSA See Canada Consumer Product Safety Act.


See Code of Federal Regulations.

Child-Care Article

A consumer product designed or intended by the manufacturer to facilitate sleep for or the feeding of children ages three and younger, or to help such children with sucking or teething.

Children’s Product

The CPSIA defines a children’s product as designed and intended primarily for use by a child 12 years of age and younger. Recent clarifications stress not just the word “primarily” but also “for use.” Manufacturers should refer to the CPSC’s 10 Questions, Final Interpretative Rule on the definition of a children’s product and PPAI’s webinar on this topic.

Children’s Product Certificate (CPC)

A statement with testing results from a CPSC-recognized lab required by the CPSIA that the product meets or conforms with federal safety rules, bans, standards or regulations. The CPC previously was referred to as a Certificate of Conformity (COC).

Children’s Toy

A consumer product designed or intended by the manufacturer for a child 12 years of age or younger for use by the child when the child plays.

Choking Hazard

The risk associated with a children’s product or toy having detachable parts that could be choked on by a child. Consumer product safety law bans toys and other articles that are intended for use by children three years of age or younger and that are or have small parts, or that produce small parts when broken. Toys and games that are or contain small parts and that are intended for use by children three to six years of age must be labeled to warn consumers not to purchase them for children younger than three because those children could choke on the small parts.

Code of Federal Regulations (CFR)

A collection of rules published in the Federal Register by the executive departments and federal agencies.

Component Testing

Manufacturers can rely on test results or certification from a component part supplier. Component testing can reduce redundant testing. For example, if the identical button is used on five styles of children’s sweaters, the button can be tested once as a component rather than tested with each of the five styles of sweaters. Component testing can also identify test failures early on by testing a component before it is applied to the finished product and tested at that stage. Component testing may offer a marketing advantage to many component part suppliers who will promote the sale of pre-certified CPSIA compliant products. With component testing, though, it is critical that there is good traceability to the finished product and that the manufacturing process does not contaminate the component or final product.

Composite Testing

Composite testing is allowed for paints and substrates for lead and phthalates testing. You may test a combination of component parts as long as test procedures are followed to ensure that no failure to comply with applicable limits will go undetected.

Consumer Product

Any article, or component thereof, produced or distributed for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or otherwise, or for personal use or consumption.

Consumer Product Safety Commission (CPSC)

The U.S. Consumer Product Safety Commission is the government agency charged with protecting the public from unreasonable risks of serious injury or death from thousands of types of consumer products under the agency’s jurisdiction. Consumer Product Safety Improvement Act (CPSIA) Passed in 2008, a public law that made significant changes to product safety laws and gave the Consumer Product Safety Commission (CPSC) significant new responsibilities for ensuring the safety of consumer products.


See Children’s Product Certificate.


See Consumer Product Safety Commission. CPSIA See Consumer Product Safety Improvement Act. Decorator Anyone who embellishes a product either through screen print, painting or embroidery. Endocrine Disruptor Any chemical that may interfere with the endocrine system and have negative developmental and reproductive effects in humans. Chemicals such as BPA that are thought to be possible endocrine disruptors are frequently found in plastic bottles or metal food containers. Estrogenic Properties Chemical characteristic found in some plastics such as BPA that imitate the hormone estrogen. Chemicals with estrogenic properties are endocrine disruptors.


See Food and Drug Administration.

Federal Hazardous Substances Act (FHSA)

A public law that requires that certain hazardous household products (“hazardous substances”) bear cautionary labeling to alert consumers to the potential hazards that those products present and to inform them of the measures they need to protect themselves from those hazards.


See Flammable Fabrics Act.


See Federal Hazardous Substances Act.

Fiber Identification Act

A public law requiring that all apparel must include the correct fiber content within three percentage points of accuracy. There is a five percent rule in which fibers of less than five percent should be disclosed as “other fiber” rather than the generic name.

Flammable Fabrics Act (FFA)

A public law that requires various flammability tests for clothing including the Standard for the Flammability of Clothing Textiles and the Standards for the Flammability of Children’s Sleepwear.

Food and Drug Administration (FDA)

A federal agency in the Department of Health and Human Services, established to regulate the release of new foods and health-related products as well as drinkware and tableware. GCC See General Certificate of Conformity.

General Certificate of Conformity (GCC)

A declaration of a product’s conformity to federal safety rules, bans, standards or regulations based on a test of the product or upon a reasonable testing program. GCCs vouch that a product complies with a certain requirement and may or may not involve any testing by third-party laboratories.

Generally Recognized As Safe (GRAS)

Generally Recognized As Safe (under sections 201(s) and 409 of Federal Food and Cosmetic Act): any substance that is intentionally added to food is a food additive that is subject to pre-market review and approval by the FDA, unless the substance is generally recognized among qualified experts as having been adequately shown to be safe under the conditions of its intended use, or unless the use of the substance is otherwise excluded from the definition of food additive.


See Generally Recognized As Safe.

Illinois Lead Poisoning Prevention Act

A labeling law that regulates the lead levels of children and adult items. If the surface coating or substrate material of an adult item exceeds 600 ppm, the warning label is required. For children’s products, if the total lead content of an applicable component is more than 40 ppm but less than 600 ppm the product requires a warning label.

Labeling of Hazardous Art Materials Act (LHAMA)

A public law that requires that all art materials be reviewed to determine the potential for causing a chronic hazard and labeled if determined to be potentially dangerous.


A soft, malleable heavy metal. In certain contact degrees, lead is a potent neurotoxin for animals and humans. Lead has been regulated in paint and similar surface coatings since the 1970s. The CPSIA introduced a lead content limit on accessible substrate materials of children’s products in 2008. The CPSIA limits lead in paint and lead content of substrate materials in children’s products and toys.


See Labeling of Hazardous Art Materials. Manufacturer Any company that manufactures, produces or assembles a promotional product. “Manufacturer” also includes firms that import a consumer product into the United States market or distributors who import directly from non-U.S. manufacturers.


A family of compounds used primarily to increase the flexibility an d durability of plastics. Six types of phthalates including DEHP, DBP, BBP, DINP, DIDP and DnOP are currently banned for use in children’s toys and child-care articles.

Polyvinyl Chloride (PVC) or Vinyl

Widely used plastic material that contains phthalates. The use of PVC in children’s products is regulated by the CPSIA. There are stringent limits on the amount of certain phthalates in children’s toys and child-care articles.


Parts per million

Principle Affordance

The possible actions that are afforded by the product—how the user is most likely to use or misuse a product. For example, a bucket can be used to hold cleaning products, but it can also be used by a child as a helmet or a hat when at play.