Vermont Updates Its Children’s Products Reporting Requirements

Vermont has revised its Chemicals of High Concern in Children’s Products Rule which requires 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

The new amendments add 20 chemicals to the CHCC list, which now contains 86 CCHC. The amendments also allow 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. The reporting frequency was changed from biennially to annually after the next reporting date of August 31, 2020 and requires the Universal Product Code (UPC) be included in the disclosure notice if the product has such a code.

Chemicals added included additional phthalates, lead, and lead compounds. For more information or a copy of the chemical list, please contact SGIA’s Government Affairs Department at