How do I determine if a child care article is subject to the phthalates limits?
A6: The statutory definition of child care article includes only sleeping, feeding, sucking or teething. Thus, products associated with other aspects of child care, such as bathing and diapering, are not subject to the phthalates limits. On February 12, 2009, the CPSC published draft guidance with respect to specific child care articles, and this guidance makes the distinction between primary and secondary products. A primary product is one that has direct contact with the child. It may have direct mouth contact, such as a teether or a pacifier. Or it may not have direct mouth contact, such as a bib, a blanket, a high chair, a crib teething rail. These are all considered primary products and are subject to the regulation. A secondary product is one that might be used by the parent but which has no direct contact with the child, such as a bottle warmer, bottle cleaning products, a breast pump or a highchair floor mat. These products are not subject to the regulation. So-called multiple
