How are T-shirts imprinted with a design affected by lead and phthalates requirements?
A19: The design would need to be tested for lead in surface coatings unless the design has become part of the substrate and is not scrapable. In that case, lead in substrate testing would be appropriate. The CPSC is currently considering exemptions for dyed or undyed textiles whose lead content is consistently below the lead limits, and as long as they have not undergone any treatment which would impart lead and they are not ornamented in other ways, but a final rule has not yet been issued. Because a T-shirt is neither a toy nor a child care article, it would not be subject to the phthalates requirements.