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Overview

Over the years a great many countries outside the United States and the European Union have adopted limits on lead content or lead exposure that are often identical to those in the US and/or EU. Limits for lead in "children's jewelry" at 600 ppm and an exposure limit at 90 ppm (or 90 mg/kg) are common, though not universal. The following is an attempt to present information and links to primary resources for those countries in which TierraCast currently has customers, and is not presented as an exhaustive list of all international regulations.

Australia

In response to concerns over the safety of the lead content discovered in children's fashion jewelry and toys offered for sale in Australia, the government passed the Consumer Protection Notice No. 13 of 2007 in September 2007. This regulation, pursuant to section 65C(5) of the Trade Practices Act of 1974, sets the maximum limit of exposure to lead in toys at 90 mg/kg (ppm).

The test and report must be in accordance with the procedures and result interpretation provisions of the Australian/New Zealand Standard AS/NZS ISO 8124.3:2003 entitled "Safety of toys, Part 3: Migration of Certain Elements". The Australian government recognizes that the EU approach to similar testing under BS EN 71-3: 1995 "Safety of Toys- Migration of Certain Elements" is an acceptable equivalent to the AS/NZS Standard.

TierraCast Compliance in Australia

The Australian standard of exposure to lead in children's jewelry, at the limit of 90 mg/kg (ppm) is identical to that of the EU under Toys Safety Regulations of 1995 - Section EN 71:3. While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under Toys Safety Regulations of 1995 - Section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.

Canada

The Canadian regulations incorporate both a lead content limit comparable to that adopted by the State of California (and currently under consideration for adoption as the initial upper limit as a Federal standard in the United States) and a limit on "leachable" lead in agreement with the EU Toy Safety standards.

The Children's Jewelry Regulations came into force June 1, 2005 and permits the import, advertisement, or sale of jewelry items intended primarily for children under 15 years of age only if the items do not contain more than 600 mg/kg (ie. ppm) total lead and 90 mg/kg "migratable" lead. Health Canada offers the article "Effects of Lead on Human Health" to provide more detail on this issue.

TierraCast Compliance in Canada

Since the introduction of the cast components product line in 1991, TierraCast has used Britannia, a pewter alloy that contains no more than .05% (500 ppm) lead. In fact we have insisted on receiving shipments from our various suppliers of metal destined for our manufacturing processes that fall well below the 500 ppm level. Each of these lots is accompanied by a certification of the alloy content. A table of those shipments is available for your review that indicates that most of the shipments we have used in the manufacture of our cast components contain below 200 ppm lead.

In support we offer the results from two independent test facilities. These reports, available as .pdf files, confirm that the alloy TierraCast uses in the manufacturing of its cast pewter components tests well below the 600 ppm limit for "children's jewelry", set by the recent California legislation and that are proposed under the developing US Federal standard.

The Canadian standard of exposure to lead at the limit of 90 mg.kg (ppm) is identical to that of the EU under Toys Safety Regulations of 1995 - Section EN 71:3. While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under Toys Safety Regulations of 1995 - Section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.

Japan

Our research indicates that the Japan Toy Safety Standard ST 2002, part 3 "Chemical Properties" sets a limit of 90 mg/kg (ppm) of exposure to lead in "metal accessories" for children under the age of 14 years. This limit is in line with the requirements in Canada, Australia, New Zealand and the European Union.

TierraCast Compliance in Japan

While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under the European Union Toys Safety Regulations of 1995 - section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.

New Zealand

New Zealand has adopted regulations identical to that of Australia regarding acceptable lead levels in children's toys; in fact they share the exact testing protocol - AS/NZS ISO 8124.3:2003 entitled "Safety of Toys, Part 3: Migration of Certain Elements".

In September 2007, New Zealand adopted the Unsafe Goods (Lead in Children's Toys) Notice 2007. Highlights of that legislation (quoted directly from the web link) are:

Title (1) This notice may be cited as the Unsafe Goods (Lead in Children's Toys) Notice 2007.

This notice has effect from 20 September 2007.

Children's toys which contain lead in their accessible parts at a migration level greater than 90mg/kg of toy material are declared to be unsafe goods.

For the purposes of this notice: migration level means the value calculated after testing in accordance with the procedures and result interpretation provisions of the Australian/New Zealand Standard AS/NZS ISO 8124.3:2003 entitled "Safety of Toys, Part 3: Migration of Certain Elements".

TierraCast Compliance in New Zealand

The New Zealand standard of exposure to lead in children's jewelry, at the limit of 90 mg.kg (ppm) is identical to that of Australia and the EU under Toys Safety Regulations of 1995 - section EN 71:3. While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under Toys Safety Regulations of 1995 - Section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.

Philippines

In September 2007, the Philippine government adopted Administrative Order 2007-0032 "Regulations on the Issuance of a License to Operate to Companies that Manufacture, Import or Distribute Toys for the Philippine Market". This Order addresses safety issues for children's toys for ages under 18 years and adopts the ISO 8124-3:1997 protocol for "Migration of Certain Metals".

The limit of 90 mg/kg (ppm) of lead is in line with the requirements in Japan, Canada, Australia, New Zealand, South Africa and the European Union. In addition, the government of Australia recognizes the EU testing protocol (under EN 71-3) as equivalent to the ISO 8124-3:1997 approach. While no specific confirmation is available that the Philippines also officially accepts this equivalency, TierraCast offers the following statement of compliance.

TierraCast Compliance in the Philippines

While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under the European Union Toys Safety Regulations of 1995 - section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.

South Africa

Our research indicates that the South African SABS ISO 8124-3:1997 "Safety of Toys - Migration of Certain Elements" sets a limit of 90 mg/kg (ppm) of exposure to lead in "metal accessories" for children under the age of 14 years. This limit is in line with the requirements in Japan, Canada, Australia, New Zealand and the European Union. In addition, the government of South Africa recognizes the EU testing protocol (under EN 71-3) as equivalent to the ISO 8124-3:1997 approach. While no specific confirmation is available that South Africa also officially accepts this same equivalency, TierraCast offers the following statement of compliance.

TierraCast Compliance in South Africa

While TierraCast does not market its cast pewter components to children, it nevertheless can affirm that its silver and gold plated components do comply with those limits set under the European Union Toys Safety Regulations of 1995 - section EN 71:3 as indicated by the test results from samples submitted to Intertek Testing Laboratories.