By Quin Dodd and Charles A. Samuels
On September 29, 2010, the U.S. Consumer Product Safety Commission (CPSC) approved a final interpretative rule on the meaning of “children’s product” as used in the Consumer Product Safety Improvement Act of 2008 (CPSIA). Understanding the difference between a “children’s product” and a “general use product” is critical, since the CPSIA subjects children’s products to stringent lead limits, the tracking label mandate, and third-party testing and requirements, among other requirements. The issuance of the interpretative rule comes at a time when the safety of children’s products is receiving more scrutiny from the federal government and the CPSC is assessing record penalties for violations of federal product safety laws.