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Does the phthalate prohibition apply to inaccessible parts?

inaccessible phthalate prohibition
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Does the phthalate prohibition apply to inaccessible parts?

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The prohibition on phthalates applies to all parts of a childrens toy or child care article as defined in section 108 of the CPSIA. Section 108 does not make an exception or exemption for accessibility for phthalates as is the case for lead in childrens products under section 101.

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