Vermont Amends Chemicals of High Concern (CHCC) in Children’s Products Reporting Rule

Vermont has recently adopted a revision to the Chemicals of High Concern in Children’s Products Rule which require manufacturers who use chemicals designated as Chemicals of High Concern to Children (CHCC) to disclose information about these chemicals to the Health Department. The rule has also incorporated the amendments into a signed Bill (S.55) in June 2019. The new provisions became effective on August 15, 2019.

According to the Reporting Rule, manufacturers are required to report to the State if there is a CHCC present in any accessible components of a children’s product which is:

• intentionally added at a level above the Practical Quantitation Limit (PQL) or
• as a contaminant at concentrations of 100ppm or greater

Key Amendments in the Rule:

• Adds 20 chemicals to the CHCC list (refer to below table), the list now contains 86 CHCC
• Establishes a process and procedure on how to add or remove a CHCC from the list
• Allows the Commissioner of Health to adopt rules to regulate the sale or distribution of a children’s product containing a CHCC depending on the degree and frequency of exposure to children
• Revises the reporting frequency from biennially to annually after the next reporting date, i.e. August 31, 2020, reporting on or before August 31, 2020 will be for products offered for sale between September 1, 2018 and August 31, 2020
• Requires Universal Product Code (UPC) be included in the disclosure notice if the product has such a code

Download Bulletin PDF file to view table with list of chemicals and CAS numbers. 

Additional Information:  

Chemicals of High Concern in Children’s Products Rule:
https://www.healthvermont.gov/sites/default/files/documents/pdf/Env_CDP_chemicals_high_concern_childrens_products_rule.pdf

86 CHCC List:
https://www.healthvermont.gov/sites/default/files/documents/pdf/Env_CDP_chemicals_of_high_concern_to_children.pdf

How Does this Impact You? Contact Us to Discuss

If you have any comments and/or questions regarding these requirements, please contact your customer service representative.