Consumer Product Safety Commission

Reducing Third Party Testing Costs through Determinations Consistent with Assuring Compliance

As the CPSC considers determinations that certain materials and components of children’s products do not have to be pre-market tested, CFA strongly urges the Commission to ensure that any changes made to reduce testing burdens do not weaken product safety standards or public health protections. CFA reminds the Commission that those seeking these determinations have the burden of proof, and any information provided by manufactures to support the determination that certain materials would never contain lead, other heavy metals, or phthalates must be supported by objective scientific evidence.