The Commission also recognizes that testing and certification of books published prior to 1985 is not required for libraries and resellers because they do not typically manufacture or import children's books. Because older children's books did not use the modern CMYK printing process and some have been found to contain lead, the Commission was unable to make a determination that older books or their components do not exceed the CPSIA's lead limits.
The Commission continues to recognize that used children's books that are sold as collectors items to adults would not be considered to be “children's products” as defined by the CPSIA because as collector's items for adults such books would not be “designed or intended primarily for children 12 years of age or younger.” Accordingly, these collector's item books may be sold to adults. With respect to older children's books that are lent out, the Commission intends to issue a separate statement of policy. It is my hope that this guidance will offer common sense solutions that alleviate undue burdens on those who lend older children's books.
I encourage our stakeholders to seek more lead determinations and provide sufficient scientific information to the staff in support of requested determinations. The current set of lead determinations will not be the last, and the Commission urges all those concerned to assist in identifying additional materials that do not exceed the CPSIA's lead limits that should be included in future determinations.
Consumer product safety commission
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