This is a broad overview of ATSM toy safety standards as they relate to chemical heavy metals testing for coatings and substrates. The standards are copyrighted and periodically updated. The ASTM F963-07 standard was effective and mandatory 180 days after the enactment of the Consumer Product Safety Improvement Act (CPSIA) signed August 2008.
16 CFR § 1250.2(a) identifies the latest accepted version and the approval date. New toys must currently comply with provision ASTM F963-17, Standard Consumer Safety Specification for Toy Safety, approved May 1, 2017.
When we test a new toy using handheld XRF, sometimes the instrument detects heavy metals that are a concern from a children’s health perspective. These elements are the subject of ongoing research and toy regulation. They include antimony, arsenic, barium, cadmium, chromium, lead, mercury, and selenium.
Although total lead content is restricted to 90-100 parts per million in children’s products, the other elements mentioned above are only subject to migration testing, also known as metals solubility testing.
Testing for the migration of an element is different than screening for the mere presence of an element as we do with handheld XRF. Migration testing occurs in a lab and it simulates conditions were a child might mouth or ingest a product. Accessible components of the toy are exposed to an acidic solution and the contents are measured after a designated period. The acceptable testing protocols are laid out in the copyrighted standard. The migration limits are as follows:
Maximum soluble migrated element in parts per million (mg/kg) for surface, coatings and substrates other than modeling clay included as part of a toy:
| Antimony (Sb) | Arsenic (As) | Barium (Ba) | Cadmium (Cd) | Chromium (Cr) | Lead (Pb) | Mercury (Hg) | Selenium (Se) |
| 60 | 25 | 1000 | 75 | 60 | 90 | 60 | 500 |
The intent of the chemical testing is to limit exposure of children to toxic heavy metals that may adversely impact health.
Which Toys are Required to be Tested?
Not all toys are required to be tested for migration of toxic heavy metals. Only the accessible components of toys “likely to be sucked, mouthed, or ingested” are subject to the chemical testing. We spoke to a staff member at the Consumer Product Safety Commission who helped us navigate these restrictions:
ASTM F963-17 provides guidance on the classification of toys or parts that are likely to be sucked, mouthed, or ingested. The criteria include:
(1) All toy parts intended to be mouthed or contact food or drink, components of toys which are cosmetics, and components of writing instruments categorized as toys;
(2) Toys intended for children less than 6 years of age, that is, all accessible parts and components where there is a probability that those parts and components may come into contact with the mouth.
16 CFR § 1199.1(a), which references phthalate restrictions in toys, provides more guidance on what can be placed in the mouth:
“If a toy or part of a toy in one dimension is smaller than 5 centimeters, it can be placed in the mouth.”
The CPSC generally advises businesses to test all accessible components of toys out of an abundance of caution.
Materials Not Required to Be Tested:
Per 16 CFR § 1253.2(a), there are some types of toy materials called manufactured unfinished fibers that do not have to be tested for compliance with ASTM F963 metals solubility limits. The materials are not exempt from the standard but do not exceed it.
Those low-risk materials are:
(1) Nylon;
(2) Polyurethane (Spandex);
(3) Viscose Rayon;
(4) Acrylic and Modacrylic; and
(5) Natural Rubber Latex.
Once chemical colorants are added, the fibers are longer considered unfinished and would be subject to the testing. For example, a dyed natural latex rubber bath toy likely to be mouthed, would be required to be tested per the heavy metal limits.
Note that certain types of engineered wood products do not exceed the metals solubility limits.
Be aware there are types of children’s products that are not required to be tested for heavy metals solubility because they are not considered to be toys. Some of these items include but are not limited to: toddler drinking cups, children’s jewelry (depending on its construction and advertising), apparel, shoes, backpacks, art supplies, and hair accessories.
It doesn’t make sense to us that toys that contact food and drink are leach tested but toddler cups are not, given that trace cadmium is sometimes detected in cups made with silicone parts.
When We Find Restricted Metals in New Toys:
We inquired from staff at the Consumer Product Safety Commission about several new toy products that we have tested using XRF where we have detected trace cadmium, barium, antimony or other restricted elements.
These products include new silicone poppers, rubber bath toys, and polyester animals. The staffer stated all of these products are likely subject to the chemicals regulations. Note the use of the word “likely,” meaning there are many intricacies in the standards that do not always make the testing requirements cut and dry.
We also inquired about testing requirements for polyester stuffing inside toys, given that PET plastic typically contains antimony. We were advised that the stuffing in a toy is likely to be subject to the chemical testing if parts of the toy are less than 5 centimeters on any dimension (such as the limb of a doll, or a corner of that toy). The stuffing on these small parts, even when wrapped in fabric, is not considered inaccessible and is subject to migration testing. Clearly there are many nuances at play that are not always transparent or easy for consumers to understand.
Nonetheless, we are fortunate the regulations exist. When we test a 2008 or newer toy that can be mouthed by young children, and the accessible components contain trace antimony, or trace cadmium, or some other regulated element at a trace level, we do not generally have a concern. Other blogs may focus on the fact that these heavy metals are present at all when using XRF, but we feel it is important to add context and note when migration limits likely apply.
What About Vintage Toys?
For reference, the ASTM toy safety standard was made mandatory under the Consumer Product Safety Improvement Act (CPSIA) signed into law in August 2008. The standard became effective 180 days after signing.
It’s worth noting that vintage toys may leach unsafe quantities of regulated elements, and they may also contain high total lead and cadmium content. These issues are worth considering when evaluating the risks associated with vintage toys.
Here’s a peer-reviewed article where a scientist tested older plastic toys for regulated metals with XRF then performed migration testing. The study identified exposure hazards in used toys which leached heavy metals in violation of current safety standards. The scientist gathered secondhand products from the U.K. and tested them in accordance with European toy migration limits, but the message is applicable to vintage toys sold and reused in the United States, too.
Note that we have regulations limiting total lead content to 90-100 parts per million in products for children ages 12 and under. Products that exceed this limit are considered unsafe for kids. Vintage toys often contain high amounts of lead which we can easily detect with XRF.
Where Do We Go From Here?
Given migration testing is outside of our capability, we do not typically discuss migration testing except to mention when it is applicable for certain types of new toys.
When we review our XRF data, we focus on total content regulatory limits where they exist (both domestically in the United States and abroad). The most important standard we consider is the federal restriction on total lead exceeding 90-100 parts per million for children’s products.
However, when migration testing is performed on new toys, it improves our confidence in the product, even when trace heavy metals are detected via XRF. Obviously we prefer a toy that tests “clean” or non-detect for heavy metals, but trace levels in consumer goods do not typically concern us unless we are discussing a product that can be ingested (such as food or cosmetics, which should be tested at the parts per billion level with a lab and not with handheld XRF).
We also try not to focus too narrowly on trace heavy metals for most other types of consumer goods. We want to provide concrete, science-based information to our readers. We don’t want to apply an extreme and overly simplistic lens to our data, especially if there is no third party research to quantify a potential exposure concern. We don’t want to encourage worry, since anxiety is neither healthy nor life affirming. We have an article about overthinking non-toxic concerns if you find yourself stuck in this zone.
It’s also important to keep toy regulations in perspective since we deal with a variety of consumer goods. Some regulated elements in toys are found in abundance in adult products we use and like (such as chromium in stainless steel). In those examples, we do not have a concern for adult products given how they are typically used. But we do prioritize reducing exposure to lead and cadmium across all consumer goods, and we focus on the environmental impact of using those materials.
I think it’s important to mention here that we are not toxicologists with expertise on all the regulated elements listed in this article. That’s why we consider the opinions of experts, peer-reviewed scientists, non-profit environmental organizations, and regulatory agencies when it comes to the issue of toxic heavy metals in consumer goods.
We are primarily advocates for the public and families. We post our XRF data and leave the decision to you: parents should decide which new and regulated toys are appropriate for their kids, based on their own priorities.
I hope this article provides some background on toy safety regulations involving heavy metals solubility testing in the United States.
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