# CPSC Small Entity Compliance Guide: Lead (83 FR 28983): Lead > Federal · Agency guidance · In force URL: https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Total_Lead_Content_Business_Guidance_and_Small_Entity_Compliance_Guide ## Section - **Citation:** CPSC Small Entity Compliance Guide: Lead (83 FR 28983) - **Heading:** Lead - **Jurisdiction:** Federal - **Kind:** Agency guidance - **Status:** In force - **Text as of:** August 14, 2026 - **Source:** Compiled text - **Location:** CPSC Small Entity Compliance Guides / Lead ## Text Section 101 of the Consumer Product Safety Improvement Act, codified at 15 U.S.C. § 1278a , declares children’s products that contain more than 100 ppm lead in an accessible component to be a banned hazardous substance as that term is used in the Federal Hazardous Substances Act (FHSA). 16 C.F.R. § 1500.87 provides guidance on accessibility. Exemption from Testing The Commission has determined that certain materials are exempt from testing for total lead content: Untreated/unadulterated materials listed at 16 C.F.R. § 1500.91 Certain untreated and unfinished engineered wood products listed at 16 C.F.R. § 1252.3(a) This does NOT provide an exemption from meeting the total lead content requirement. Firms are still expected to certify compliance with the total lead content requirement in a Children’s Product Certificate (CPC). Further, if the end product as received by a consumer is found to have lead in excess of 100 ppm, the firm may still be held responsible for noncompliance. Other Exemptions or Exceptions Certain electronic components as listed at 16 C.F.R. § 1500.88 are either exempt from meeting the 100 ppm limit or are subject to a different lead content limit. Children’s product off-highway vehicles – any motorized vehicle that is manufactured primarily for use off public streets, roads, and highways; designed to travel on 2, 3, or 4 wheels; has either a straddle seat and handlebars for steering control, or a non-straddle seat, steering wheel, seatbelts, and roll-over protective structure; and includes a snowmobile – are not subject to the total lead content requirement per 15 U.S.C. § 1278a(b)(5) . Metal components of bicycles and related products (jogger strollers and bicycle trailers) are subject to a total lead content limit of 300 ppm per 15 U.S.C. § 1278a(b)(6) . In addition, such components are not subject third-party testing per 15 U.S.C. § 2063(d)(5)(B) otective structure; and includes a snowmobile – are not subject to the total lead content requirement per 15 U.S.C. § 1278a(b)(5) . Metal components of bicycles and related products (jogger strollers and bicycle trailers) are subject to a total lead content limit of 300 ppm per 15 U.S.C. § 1278a(b)(6) . In addition, such components are not subject third-party testing per 15 U.S.C. § 2063(d)(5)(B) . The Commission granted a petition allowing certain aluminum alloy components for certain children’s products to have a total lead content of up to 300 ppm ( 77 FR 20614 ). Used children’s products (except children’s metal jewelry, children’s products for which the donating party or seller knows it violates the total lead content requirement, or any other children’s product or category as determined by the Commission) are not subject to the total lead content requirement per 15 U.S.C. § 1278a(b)(7) . Ordinary books – a book printed on paper or cardboard, printed with inks and toners, bound and finished using a conventional method, intended to be read or has educational value (excludes books with play value, books designed or intended for children 3 years of age or younger, and toys or other articles sold or packaged with an ordinary book) – and paper-based printed materials – materials printed on paper or cardboard (such as magazines, posters, greeting cards, and similar products) that are printed with inks and toners and bound and finished using a conventional method – are not subject to third-party testing per 15 U.S.C. § 2063(d)(5)(A) . Certification Section 14(a)(2) of the Consumer Product Safety Act (CPSA) requires manufacturers and importers of children’s products subject to a regulation, standard, or ban enforced by the CPSC to certify that those products meet the requirements of the standard by issuing a CPC. For total lead content in children’s products, the citation to use in section 2 of the CPC is “15 U.S.C. § 1278a – Total lead content” tion 14(a)(2) of the Consumer Product Safety Act (CPSA) requires manufacturers and importers of children’s products subject to a regulation, standard, or ban enforced by the CPSC to certify that those products meet the requirements of the standard by issuing a CPC. For total lead content in children’s products, the citation to use in section 2 of the CPC is “15 U.S.C. § 1278a – Total lead content”. For more information on creating a CPC, visit our CPC business guidance page . Additional Information Total lead content FAQs FHSA business guidance page Injury Statistics and Technical Reports | Chemicals Contact For more information, please contact the Small Business Ombudsman (SBO) team: SBO contact form Toll-free: (888) 531-9070 Email: SBO@cpsc.gov ## Nearby sections - [CPSC Small Entity Compliance Guide: ASTM F963 Elements (85 FR 33015) ASTM F963 Elements](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Toy_Safety_Business_Guidance_and_Small_Entity_Compliance_Guide.md) - [CPSC Small Entity Compliance Guide: Certificates of Compliance (90 FR 1800) Certificates of Compliance](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Certificates.md) - [CPSC Small Entity Compliance Guide: Conditions and Requirements for Relying on Component Part Testing or Certification, or Another Party’s Finished Product Testing or Certification, to Meet Testing and Certification Requirements (76 FR 69545) Conditions and Requirements for Relying on Component Part Testing or Certification, or Another Party’s Finished Product Testing or Certification, to Meet Testing and Certification Requirements](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Component_Part_Testing.md) - [CPSC Small Entity Compliance Guide: Full-Size Baby Cribs (75 FR 81765) Full-Size Baby Cribs](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Full_Size_Baby_Cribs.md) - [CPSC Small Entity Compliance Guide: Lead (83 FR 28983) Lead](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Total_Lead_Content_Business_Guidance_and_Small_Entity_Compliance_Guide.md) - [CPSC Small Entity Compliance Guide: Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates (82 FR 49938) Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Phthalates_Information.md) - [CPSC Small Entity Compliance Guide: Requirements Pertaining to Third Party Conformity Assessment Bodies,16 CFR parts 1112 and 1118 (78 FR 15835) Requirements Pertaining to Third Party Conformity Assessment Bodies,16 CFR parts 1112 and 1118](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Lab_Accreditation.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Adult Portable Bed Rails (88 FR 46958) Safety Standard for Adult Portable Bed Rails](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Adult_Portable_Bed_Rails.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Baby Changing Products (83 FR 29672) Safety Standard for Baby Changing Products](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Baby_Changing_Products_Business_Guidance_and_Small_Entity_Compliance_Guide.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Bassinets and Cradles (78 FR 77574) Safety Standard for Bassinets and Cradles](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Bassinets_and_Cradles.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Bedside Sleepers (79 FR 2581) Safety Standard for Bedside Sleepers](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Bedside_Sleepers.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Booster Seats (83 FR 30837) Safety Standard for Booster Seats](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Booster_Seats_Business_Guidance_and_Small_Entity_Compliance_Guide.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Carriages and Strollers (79 FR 13208) Safety Standard for Carriages and Strollers](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Carriages_and_Strollers.md) - [CPSC Small Entity Compliance Guide: Safety Standard for Clothing Storage Units (87 FR 72598) Safety Standard for Clothing Storage Units](https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Clothing_Storage_Units.md) --- Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CPSC_SECG_Total_Lead_Content_Business_Guidance_and_Small_Entity_Compliance_Guide. 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