CU comments on children’s jewelry containing lead


Comments of Consumers Union of U.S., Inc. and Consumer Federation of America
to the U.S. Consumer Product Safety Commission
on “Children’s Jewelry Containing Lead; Advance Notice of Proposed Rulemaking;
Request for Comments and Information”

Introduction
Consumers Union (CU), publisher of Consumer Reports®, joined by Consumer Federation of America, (jointly “We”) submits the following comments in response to the U.S. Consumer Product Safety Commission’s (“CPSC” or “Commission”) abovereferenced Advance Notice of Proposed Rulemaking (“ANPR”) on children’s jewelry
containing lead. The CPSC has published this Notice seeking comments and information on the health risks associated with lead in children’s jewelry, and potential regulatory options to address these risks, particularly a ban on products containing more than 0.06%, by weight (“0.06%”) lead under the Federal Hazardous Substances Act.
We strongly support the proposed ban as an important step forward in protecting children from the hazards of lead exposure, for many reasons, including: (i) the serious harm that can result from exposure to lead by children; (ii) the increasing presence on the U.S. market of lead in products intended for use by children; (iii) the difficulty of identifying unsafe products; and (iv) the inability of the recall system to locate and recapture, low-cost, unbranded products. In addition, we strongly urge the CPSC to take stronger action to protect children from lead hazards in other products.
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