Metals in Children's and Consumer Products and Packaging

Overview

This Washington State Department of Ecology Hazardous Waste and Toxics Reduction Program publication (Stone 2021, Publication 14-04-014, Revised June 2021) is a multi-category screening survey of ten metals — antimony (Sb), arsenic total arsenic (tAs), cadmium (Cd), total chromium (Cr), cobalt (Co), copper (Cu), lead (Pb), total mercury (tHg), molybdenum (Mo), and zinc (Zn) — in children’s products, their packaging, and consumer products sold in Washington State. The study supports three regulatory objectives: (i) evaluating compliance with the Washington Children’s Safe Products Act (CSPA, Chapter 70.240 RCW) for the six Chemicals of High Concern to Children (CHCC) metals Sb, tAs, Cd, Co, tHg, and Mo; (ii) evaluating compliance with Washington’s toxics-in-packaging legislation (Chapter 70.95G RCW), which restricts the sum of mercury (Hg), Cd, Pb, and hexavalent chromium (Cr-VI) to 100 ppm in packaging; and (iii) measuring concentrations of two Puget Sound water-quality metals of concern (Cu and Zn). Funded by the Washington State Attorney General’s Office. Laboratory analysis performed by ALS Environmental using ICP-MS (nine metals) and cold-vapour atomic absorption (CVAA, mercury). Across 150 children’s-product component samples, lead, cobalt, and antimony were the most commonly detected CHCC metals; antimony reached the highest CHCC detection (>100 ppm in 8 of 150 samples). Total chromium reached 13,600 ppm (1.36%) in a metal baby-spoon sample. Across 26 packaging samples, only one component exceeded the 100 ppm packaging-legislation limit — a dog-toy plastic packaging at 738 ppm Pb (7.4× the limit), for which the manufacturer was notified of the compliance failure. Across 150 Puget-Sound-metals samples, zinc and copper were found in 19 and 9 components, respectively, at concentrations above 100,000 ppm (10%), primarily in metal buttons, zippers, and zipper pulls. Ecology initiated compliance correspondence with 12 manufacturers for 19 results indicating possible CSPA reporting non-compliance, and identified 2 results indicating possible lead-restriction violations under CSPA / federal CPSIA, which were forwarded to the U.S. Consumer Product Safety Commission for federal-law assessment.

Key numbers

Sample frame

• Children’s products purchased: 101 children’s products, separated into 150 individual component samples for laboratory analysis (p. 1 abstract, p. 7 Table 1 caption, p. 9 narrative).
• Total components first XRF-screened across study scope: 1,614 components — 1,359 children’s-product components from 407 products plus 387 packaging components from 255 packages (p. 5).
• Packaging items analysed: 24 packaging items, broken down into 25 individual packaging-component samples sent to the contract laboratory (p. 18, p. 19 Table 4).
• Puget-Sound metals frame: 102 products separated into 150 components analysed specifically for copper and zinc (p. 24, p. 25 Table 7).
• Retailer sourcing: local Washington stores and internet retailers (p. 4).
• Purchase context: Sampling occurred prior to Halloween 2012 for the Halloween accessories subset (p. 28).
• Screening instrument: Niton XL3t 700 XRF analyser (p. 5, p. 18).
• Confirmatory instrumentation: ICP-MS for nine metals; cold-vapour atomic absorption (CVAA) for mercury; analyses conducted at ALS Environmental under contract (p. 5).
• Funding: Washington State Attorney General’s Office (Acknowledgements, p. ii).

Children’s products: ten-metal detection distribution (Table 3, p. 10)

n = 150 component samples (six CHCC metals plus lead and chromium reported here; copper and zinc reported separately in the Puget Sound section).

Lead, cobalt, and antimony were the most commonly detected; antimony reached the highest CHCC values (8 samples in the 100–<1,000 ppm bucket). Mercury was found in only 3 samples, two of which were near the method detection limit (p. 10).

Children’s products: category-level distribution (Table 2, p. 9)

Children’s products: highest detected values by category (Figures 3–9, p. 11–17)

• Baby and bath accessories (Figure 3, p. 11): Sb in a baby bib at 116 ppm and a second baby bib at 99.6 ppm; mesh food sacks at 72.1 ppm Sb; body wash at 55.5 ppm Sb; baby wipes at 70.6, 61.3, and 40.6 ppm Sb; tummy play pad at 36.9 ppm Sb. Co at 36.9 ppm in sample DT033-b01, which the Figure 3 narrative calls a baby cream but which Table 4 (PDF p. 25, printed p. 19) lists as product packaging; the result describes the cream’s container, not the cream (see the baby powder and packaging subsection below). Cr in a set of metal baby spoons at 13,600 ppm (1.36%) — the highest single metal concentration reported in the children’s-products section. Mercury at 0.3 ppm in baby spoons, baby toothbrush, and bath salts (near method detection limit).
• Clothing (Figure 4, p. 12): Co range from low values up to 560 ppm in clothing, with 6 of 31 clothing samples (20%) at or above 100 ppm Co — agency notes this is consistent with manufacturer-reported cobalt use as a textile dye. Sb at 121 and 128 ppm in jeans. Pb detected in every clothing sample tested, at low levels; 12 samples between 10 and 70 ppm Pb. Cr at 257 and 242 ppm, primarily in jeans. Mercury at 2.8 ppm reported in a boy’s space-themed footie pajamas sample (TG023) — reason unknown per the agency narrative.
• Cosmetics and accessories (Figure 5, p. 13): Co and Pb the most commonly detected CHCC metals, all at or below 35 ppm. Cr in the external pouch of one makeup pack at 157 ppm. No mercury detected.
• Halloween accessories (Figure 6, p. 14): Sb, Co, and Pb at the 30–50 ppm level in several samples. Cr at 85.3 ppm in a Halloween variety makeup pack; several other samples in the 2–30 ppm Cr range. No mercury detected.
• Jewelry (Figure 7, p. 15): Pb the most commonly detected CHCC metal (in all but one sample), ranging from low values up to 134 ppm in a plastic-earrings component. tAs at 125 ppm in another part of the same plastic earrings. Sb >100 ppm in two jewelry items (a character-licensed ring at 189 ppm and a pendant at 219 ppm). Cr at the highest jewelry concentrations: 441 and 432 ppm in two plastic-earring components, plus additional samples in the 100+ ppm range.
• Lip balm samples (Figure 8, p. 16): Lip balm itself showed low metal levels; lip-balm containers and related components showed higher concentrations. tAs at 276 ppm in a metal chain from a keychain-and-lip-balm set; Sb at 156 ppm in a plastic tube containing lip balm; tAs at 72.5 ppm and Sb at 35.3–38.1 ppm in other component samples. Cr in three lip-balm components ranged 91–350 ppm. No Cd or Hg detected.
• Toy components (Figure 9, p. 17): Sb the only CHCC metal >90 ppm, at 168 ppm in an orange stuffed-fish component and 94 ppm in a plastic squishy book. Cr at 144 ppm in a foil puzzle. No mercury detected.

Baby powder and baby-cream and petroleum-jelly packaging (Appendices 1 to 3)

Three samples in the report fall in the baby lotion and powder scope. Values in ppm as printed. The report prints 0.0 in many cells and does not define it or state a reporting limit, so 0.0 is not read as zero. The companion quality assurance plans list 1.0 ppm reporting limits for Sb, arsenic (As), Cd, and Pb, and printed values below that level are recorded as printed only.

Printed page 7 (PDF p. 13) explains that samples meeting both the children’s-product and packaging definitions appear in both result sets. The two “-b” samples are listed in Table 4 as packaging. No baby cream or petroleum jelly contents were analysed. The baby powder is the only baby topical product content in the report. Appendix 2 prints Zn for the jelly container as 18.80 and for the cream container as 5.60.

Children’s products: compliance outcomes (p. 17–18)

• Ecology initiated compliance correspondence for 19 metals results.
• Antimony was the most common subject of compliance correspondence (10 results), followed by cobalt (6 results).
• 12 letters sent to manufacturers. In 10 cases, the manufacturer was in compliance with CSPA because the company’s annual sales were below the CSPA reporting-rule phase-in threshold.
• 2 results indicated possible violations of the CSPA Pb restriction (RCW 70.240.020). Manufacturers were notified and Ecology forwarded the data to the U.S. Consumer Product Safety Commission (CPSC) for evaluation under the federal Consumer Product Safety Improvement Act (CPSIA).

Product packaging: ten-metal detection distribution (Table 6, p. 20)

n = 26 packaging-component samples.

Packaging compliance (p. 20)

Washington State toxics-in-packaging legislation (Chapter 70.95G RCW) restricts the sum of mercury, cadmium, lead, and hexavalent chromium to 100 ppm in packaging sold within the state (p. 18).

• Khaki curtain packaging at near the 100 ppm limit; within laboratory operating variability, no enforcement action taken (p. 20).
• Dog-toy plastic packaging (TG039) at 738 ppm Pb — 7.4× the 100 ppm limit. The manufacturer was contacted and told of the failure to comply; packaging is no longer used and additional products from the manufacturer will be purchased to verify continued compliance (p. 20, p. 23).
• Total chromium reported up to 269 ppm (a tin box holding a puzzle) and 144 ppm (a foil puzzle), but as the 100 ppm limit applies only to hexavalent chromium (Cr-VI) and the reported values include both Cr-VI and Cr-III, no non-compliance can be established without further speciation analysis (p. 22, p. 24).
• Total chromium in a cosmetic-makeup-box packaging at 153 ppm — same Cr-VI/Cr-III speciation caveat (p. 22).

Packaging: highest detected values by category (Figures 10–13, p. 21–24)

• Baby and bath packaging (Figure 10, p. 21): Sb at 95.8 ppm in moist baby-wipes packaging; Cu at 62.3 ppm in baby-wipes packaging.
• Cosmetic packaging (Figure 11, p. 22): Cu at 266 ppm and Zn at 314 ppm in a makeup-pack and cosmetic-box, respectively; Cr at 157 ppm and 153 ppm (Cr-VI / Cr-III mixture).
• Miscellaneous packaging — housewares, dog toys, etc. (Figure 12, p. 23): Zn at 902,000 ppm (90.2%) and 884,000 ppm (88.4%) in zippers from plastic pouches holding curtain sets; Cu at 4,230 and 3,740 ppm in the same curtain-pouch zippers. Dog-toy packaging at 557 ppm Cu and 738 ppm Pb (the compliance-failure sample).
• Toy packaging (Figure 13, p. 24): Zn from 912,000 ppm (91.2%) to 963,000 ppm (96.3%) in zippers from plastic pouches holding three toys; Cu also at appreciable concentrations 134–400 ppm in toy packaging; Cr at 269 and 144 ppm in tin-box-and-foil puzzle packaging (Cr-VI / Cr-III mixture).

Copper and zinc distribution (Puget Sound metals): all-component summary (Table 9, p. 28)

n = 149 individual product components.

Zinc was more often found at high concentrations than copper: 19 zinc components vs 9 copper components were >100,000 ppm (10%). Conversely, copper had 31 samples <1 ppm versus 1 zinc sample <1 ppm (p. 28).

Copper and zinc: highest detected values by category (Figures 14–21, p. 29–36)

• Baby and bath accessories (Figure 14, p. 29): A toothbrush with Cu 8,300 ppm (0.83%) and Zn 51,800 ppm (5.18%); tummy play pad at Cu 6,700 ppm; fresh-food feeders at Zn 9,640 ppm.
• Clothing (Figure 15, p. 30): 12 of 31 clothing samples were primarily metal alloys of Cu and Zn (metal buttons and zippers). Reported values up to Cu 690,000–700,000 ppm and Zn 1,080,000–1,230,000 ppm in button and zipper components (per the agency note in footnote 10, ±25% variability means analytical results up to 1,250,000 ppm are interpreted as the component being primarily that metal). A jeans button at Cu 44,000 ppm (4.4%) and Zn 8,670 ppm (0.87%); white children’s underwear at Zn 1,800 ppm (0.18%).
• Cosmetics (Figure 16, p. 31): A plastic-package zipper pull at Zn 1,090,000 ppm (109%, interpreted per the alloy convention); a plastic cosmetic-storage box at Cu 266 ppm and Zn 153 ppm.
• Footwear (Figure 17, p. 32): Shoe insert at Zn 16,000 ppm (1.6%); metal grommet in baby shoes at Cu 14,000 ppm (1.4%); baby sandals sole at Zn 5,379 ppm; yellow baby mud boots insole at Zn 4,090 ppm; pink baby ballet slippers shoe insert at Zn 4,040 ppm.
• Halloween accessories (Figure 18, p. 33): Two zipper pulls primarily zinc, at 912,000 ppm and 959,000 ppm; a composite of three black crayons at Zn 329 ppm.
• Jewelry (Figure 19, p. 34): Four samples primarily zinc with values 981,000–1,260,000 ppm (98.1%–126%, interpreted per alloy convention). Beads at Cu 144,000 ppm (14.4%); earring backing at Cu 66,100 ppm (6.61%); ring backing at Cu 80,900 ppm (8.09%).
• Lip-balm components (Figure 20, p. 35): Two metal chain portions of keychains at Cu 43,200 ppm (4.32%) and Cu 38,300 ppm (3.83%); lower copper levels of 258 and 119 ppm in lip-balm composite samples.
• Toy components (Figure 21, p. 36): Cu 154 ppm in a puzzle box lid; Zn 151 ppm in a plastic whistle body; remaining samples at trace levels.

Methods (brief)

Children’s and consumer products were purchased from local stores and internet retailers, with sampling emphasis on products designed to be applied to skin or ingested. Products were separated into three components when applicable: packaging, container, and product itself (the contents). Depending on construction, containers were further separated into sub-components per the CSPA reporting rule (Chapter 173-334 WAC).

Children’s products were purchased per three CSPA Quality Assurance Project Plans for parabens (Ecology 2012a), phthalates (Ecology 2012b), and formaldehyde/VOCs (Ecology 2012c). Packaging was analysed under a separate QAPP (Ecology 2012d). All 1,614 product, component, and packaging items were first scanned with a Niton XL3t 700 X-Ray Fluorescence (XRF) analyser following the QAPP screening protocols (p. 5). Components showing appreciable XRF concentration of any metal of concern were prioritised and sent to the contract laboratory for confirmatory analysis. 150 children’s-product components plus 25 packaging components were submitted (p. 5, p. 18).

Sample prioritisation hierarchy: highest priority to product components with appreciable XRF levels of the six CHCC metals (Sb, tAs, Cd, Co, tHg, Mo); next those containing the two additional toxics-in-packaging analytes (Pb, total Cr as a potential indicator of Cr-VI presence); lastly the two Puget Sound metals (Cu, Zn) (p. 5).

Confirmatory laboratory analysis was performed by ALS Environmental under contract, using inductively coupled plasma mass spectroscopy (ICP-MS) for nine metals (Sb, tAs, Cd, Cr, Co, Cu, Pb, Mo, Zn) and cold-vapour atomic absorption (CVAA) for mercury (p. 5). The report text does not print EPA 3052 or EPA 6020. The citation on that sentence is “(Ecology, 2021a; 2012b; 2012c; 2012d)“. Elsewhere the same report cites Ecology 2012a through 2012d, Ecology 2011a through 2011d, and Ecology 2013a through 2013d. The bibliography’s 2012a through 2012d titles and page counts match the four opened plans: 12-07-021 (parabens, 22 pages), 12-07-023 (phthalates in children’s products, 20 pages), 12-07-022 (packaging, 20 pages), and 12-07-024 (formaldehyde and VOCs, 24 pages). The methods narrative swaps the formaldehyde plan and the packaging plan relative to that bibliography. Those plans specify EPA 3052 and EPA 6020, with a reporting limit of 1.0 ppm for antimony, arsenic, cadmium, lead, and, where chromium is listed, total chromium, and 0.1 ppm for mercury on an ICP-MS row. The plan narratives also say cold-vapor atomic absorption for mercury. None of the four plans names a wipe. Printed wipe values below 1.0 ppm, including lead at 0.4 and 0.8 ppm and chromium at 0.5 and 0.6 ppm, are not restated here as less-than the plan reporting limit. A printed 0.0 stays the table value. Hexavalent chromium analysis was not performed; total chromium results reflect the sum of both Cr-VI and Cr-III. Method detection limits supported reporting at less than 1 ppm in most products, suggesting the 1 ppm practical quantitation limit in Ecology’s CSPA Reporting Guidance could be lowered (p. 1 abstract).

Sample cryomilling and analysis were performed by ALS Environmental (Acknowledgements, p. ii). All data results were within the quality assurance and quality control parameters established within the applicable QAPPs (p. 5). Because of variability inherent in chemical analyses, any sample result that is ±25% of 1,000,000 ppm is interpreted as the product component being primarily that metal; copper or zinc analytical results reported as high as 1,250,000 ppm are therefore taken as indicating an alloy primarily of that metal (footnote 10, p. 30).

Cadmium was initially omitted from analysis in some QAPPs (e.g., Parabens and Metals in Children’s Cosmetic and Personal Care Products, Ecology 2008a) due to concerns about possible federal preemption of CSPA by CPSIA. After preliminary results, cadmium was added to all remaining analyses; “NA” (Not Analyzed) is used in Appendix 1 where cadmium was not requested or reported (p. 5). No unannounced duplicates were run for metals; one announced duplicate (bubble bath packaging WM003) was submitted but no comparison was possible because no other packaging sample was submitted for the same product (p. 5).

Regulatory context

This study supports compliance assessment under three Washington State statutory regimes:

• Children’s Safe Product Act (CSPA, Chapter 70.240 RCW, 2008): Requires manufacturers to report the presence of the six CHCC metals (Sb, tAs, Cd, Co, tHg, Mo) in all components of children’s products at or above the 100 ppm CHCC reporting threshold. Also restricts Cd and Pb in children’s products; the CSPA Pb restriction was largely preempted by the federal Consumer Product Safety Improvement Act (CPSIA, 2008) (p. 3).
• CSPA Reporting Rule (Chapter 173-334 WAC, finalised June 2011): Implements the CSPA, lists 66 chemicals or chemical classes (including six metals) to be reported, and includes a phased-in schedule based on manufacturer annual sales and product use category (p. 3).
• Packages Containing Metals law (Chapter 70.95G RCW, 1991): Restricts the sum of mercury, cadmium, lead, and hexavalent chromium to 100 ppm in packaging sold in Washington. Ecology administers but has no penalty authority; non-compliant products may be banned from sale if the company refuses to comply (p. 3).
• Toxics in Packaging Clearinghouse (TPCH): Washington joined the TPCH in 2007, a nine-state association with harmonised toxics-in-packaging legislation; this study supports TPCH compliance assurance (p. 4).

Implications

• Children’s-product compliance baseline (WA state, CSPA). This study is the agency’s multi-category 2012–2013 baseline survey of CHCC and packaging-restricted metals across baby and bath accessories, clothing, cosmetics, footwear, Halloween accessories, jewelry, lip balm, and toys sold in Washington retail and online channels. The detection-frequency picture for the six CHCC metals (lead in 71% of 150 components, cobalt in 65%, antimony in 57%, molybdenum in 31%, cadmium in 31%, arsenic in 17%, mercury in 3%) is the agency-reported initial-period non-compliance signal, with 19 results triggering manufacturer compliance correspondence and 2 results forwarded to CPSC for federal Pb-restriction evaluation. The study does not propose new thresholds; it documents exceedance of the CSPA 100 ppm CHCC reporting threshold and the federal CPSIA Pb restriction in specific children’s-product components. The 2015 baseline survey of children’s jewelry Cadmium and Other Metals in Children's Jewelry (WSDOE Publication 16-03-007) and the 2018 follow-up Cadmium and Other Metals in Children's Jewelry 2018, Follow-up Study (WSDOE Publication 23-03-004) are subsequent jewelry-specific follow-ups to this 2012–2013 baseline.

• HMTc audit implications. For any HMTc certification work that addresses children’s products in the categories surveyed (baby and bath accessories, infant and children’s clothing, children’s jewelry, children’s lip balm and cosmetics, children’s makeup, children’s nail polish, face paint, pacifiers and sucking/teething aids, toothbrushes), this study provides the agency-tested 2012–2013 baseline distribution of 10 metals (Sb, tAs, Cd, Cr, Co, Cu, Pb, tHg, Mo, Zn) across 150 component samples. The XRF-screening-then-ICP-MS prioritisation methodology is a credible upper-tail-targeting design; the resulting distribution is the upper-tail picture, not a random-sample picture, and HMTc threshold-setting that cites this study should preserve that distinction. The category-level finding — that the highest CHCC concentrations occur in narrow component classes (metal baby spoons for Cr; jeans for Co; baby bibs for Sb; metal jewelry components for Pb, tAs, Cr; lip-balm metal containers and chains for Sb, tAs; metal buttons and zippers across categories for Cu and Zn) — is the actionable contamination-platform finding for downstream Step 0 Lock work on each of these product categories.

• Packaging baseline (WA state, Chapter 70.95G RCW). The packaging analysis demonstrated improved manufacturer compliance with Washington’s toxics-in-packaging legislation: of 26 packaging-component samples, only one (dog-toy plastic packaging at 738 ppm Pb) failed the 100 ppm sum-of-four-metals limit at a level requiring enforcement action. The widespread occurrence of total Cr at packaging concentrations of 100–269 ppm cannot be assessed against the law without Cr-VI speciation analysis, a methodological gap the agency notes (p. 22, p. 24).

• Puget Sound water-quality context. Copper and zinc — both negatively impacting aquatic species, particularly fish development, in Puget Sound — were found at percent-by-mass concentrations primarily in metal buttons, zippers, and zipper pulls in clothing, jewelry, footwear, cosmetics packaging, lip-balm components, and Halloween accessories. The agency cites the U.S. Fish and Wildlife Services finding (Eisler 1993) that mixtures of zinc and copper are more-than-additive in toxicity to aquatic organisms. The Puget-Sound-metals component is not a CSPA / CHCC compliance question but a regional water-quality-loading observation about consumer-product material composition.

• App. Not directly relevant to ingredient contamination_profile data because no food-matrix occurrence values are reported. Relevant to a future children’s-product screening surface that explains why metal components in children’s jewelry, metal baby utensils, metal buttons and zippers in clothing, and metal containers in lip-balm sets can be material-composition Pb, Cd, Cr, Sb, As, Cu, and Zn sources by ingestion (small parts that can be mouthed by young children) or by skin contact (jewelry, buttons against skin).

• Courses. Worked example for the regulatory-compliance module of how a state agency uses XRF screening of large component populations to prioritise samples for confirmatory ICP-MS analysis under a per-product-class compliance-monitoring statute (CSPA Chapter 70.240 RCW). Also a primary-source illustration of the gap between (i) the substance-level restriction limits in statute (40 ppm Cd, 90 ppm Pb under federal CPSIA), (ii) the contaminant-reporting threshold (100 ppm CHCC under Chapter 173-334 WAC), and (iii) the packaging sum-of-four-metals limit (100 ppm under Chapter 70.95G RCW) — three independent regulatory thresholds operating concurrently on the same children’s-product population.

• Microbiome. Not applicable. No biological matrix and no exposure-pathway measurements relevant to gut microbiome interaction.

Related evidence

• Lead
• Cadmium
• Antimony
• Arsenic, Total
• Chromium
• Cobalt
• Copper
• Mercury, Total
• Molybdenum
• Zinc
• Baby wipes
• Bibs
• Children's Jewelry
• Children's Lip Balm, Mineral-Bearing (tinted or SPF)
• Children's Makeup (ages 0-5)
• Children's Nail Polish (ages 0-5)
• Face Paint
• Clothing (onesies, pajamas, outerwear)
• Pacifiers and sucking/teething aids
• Toothbrushes (manual, electric heads)

Update history

No substantive edit history is available in this build. The full commit record is available in git.