ElanoryaUnited States federal, read 20 August 2026
Each lead figure CPSC publishes reads a different layer of the product
Two lead figures sit on CPSC's own pages for children's products. Taken away from the sentences that carry them, they can look like a strict version and a lenient version of one test. The agency that publishes them counts them as two, and the second one runs on a definition that names electroplating among the things it does not cover.
Two requirements, counted as two on the page that publishes them
The United States Consumer Product Safety Commission publishes both figures on the same page, and it opens by counting them: “There are two distinct requirements concerning lead in children's products:”. That sentence is the first fact of this reading, because it settles the question of whether the two numbers are competing versions of one test.
The first requirement is stated as a content figure: “Accessible components of children's products manufactured in or imported into the United States must not contain more than 100 parts per million (ppm) of total lead content.” The second is stated about coatings: “Paint and similar surface coatings used in children's products must not contain a concentration of lead greater than 0.009 percent (90 parts per million).”
The percentage and the parts-per-million figure in that second sentence stand inside CPSC's own parenthesis. No unit conversion is performed on this page, and none is needed to read the two sentences: the equality belongs to the source. Content limits and extraction or migration measures are different measures, and the pages read give no conversion between them either.
Which part of the product the content figure is applied to
The content requirement is not stated about the product as a single object. CPSC writes: “All accessible component parts of the children's product must comply with the total lead limits requirement. 16 C.F.R. § 1500.87 provides guidance on accessibility.”
Two things follow from the wording alone. The unit the requirement is applied to is the accessible component part, and the question of what counts as accessible is referred out to a separate section rather than answered in the sentence. That section is not reproduced here; this page records only that the referral exists.
What part 1303 declares, and in what terms
The second requirement is written as a ban. CPSC states: “16 C.F.R. part 1303 declares paints or similar surface-coating materials that contain 0.009% or more lead by weight to be banned hazardous products under sections 8 and 9 of the Consumer Product Safety Act. Children's products and furniture articles that use paints or similar surface-coating materials that contain 0.009% or more lead by weight are also banned hazardous products.”
The class of the figure matters as much as its size. It operates inside a ban: a coating at or above it is declared a banned hazardous product, and so is a children's product or furniture article that uses one. It is not a score, a grade or a safer-versus-less-safe scale, and the pages read attach no weighting or ranking to it.
The definition part 1303 runs on, and the three processes CPSC says do not meet it
A ban written about “paints and other similar surface-coating materials” reaches whatever its definition covers. CPSC reproduces that definition from 16 CFR § 1303.2(b)(1) and then names three processes that fall outside it.
- The definition is written about a material that changes to a solid film on a surface.
- As CPSC reproduces it, the term means “a fluid, semi-fluid, or other material, with or without a suspension of finely divided coloring matter, which changes to a solid film when a thin layer is applied to a metal, wood, stone, paper, leather, cloth, plastic, or other surface.”
- Three processes are named as not meeting that definition.
- CPSC's next sentence: “Printing inks that become part of the substrate, electroplating, and ceramic glazing do not meet this definition and, therefore, are not subject to 16 C.F.R. part 1303.” Electroplating is named there by process, in a list of three.
- That sentence states reach, not composition.
- What it settles is which part of the regulations applies to those processes. It states nothing about how much lead a plated, glazed or printed surface contains, and this page adds nothing to it.
Categories where CPSC states a different content figure
The content figure is not one number across every category. CPSC's Total Lead Content page names categories that carry a different limit or an exemption. They appear here only to show that the figure is category-dependent. None of them is written about jewelry, none is adapted to it here, and none is presented as an exemption available to anything else.
- Metal components of bicycles and related products: 300 ppm.
- “Metal components of bicycles and related products (jogger strollers and bicycle trailers) are subject to a total lead content limit of 300 ppm per 15 U.S.C. § 1278a(b)(6).”
- Certain aluminum alloy components: up to 300 ppm, by petition.
- “The Commission granted a petition allowing certain aluminum alloy components for certain children's products to have a total lead content of up to 300 ppm (77 FR 20614).”
- Certain electronic components: exempt, or subject to a different limit.
- “Certain electronic components as listed at 16 C.F.R. § 1500.88 are either exempt from meeting the 100 ppm limit or are subject to a different lead content limit.”
Regions this reading leaves alone
The boundaries below are part of the reading, not omissions from it. Each one marks a place where the sources read give nothing, or where the subject belongs elsewhere.
- Whether a particular piece falls inside the children's-product category at all. That question is not addressed on this page.
- The text of ASTM F2923 and of CPSC-CH-E1004-11. Neither was obtained, and ASTM F2923 is a paid standard, so no threshold, protocol, clause, annex number or version history from either appears here.
- Any jurisdiction other than United States federal, including United States state law. Nothing here is written about another regime, and nothing here transfers to one.
- Testing, laboratory work, screening and certification, whether as services, as arrangements or as steps.
- Cadmium, nickel release, phthalates and other substance figures. The pages read state no such figure for jewelry, so none is written here.
- How the two requirements interact on a given component. The record read does not resolve it, and the gap is left visible rather than filled.
A photograph is not a material reading
Elanorya's product line makes images. It does not identify plating, coating, glazing or substrate from a photograph, it measures lead in nothing, and it has no view on which requirement any piece falls under. No output of it, at any level of quality, is evidence about a material or about a category.
Nothing on this page is a check that a piece, a listing or an image can pass. It is a reading of two published texts, and it ends where those texts end.
Questions
Are the two figures two settings of the same test?
Not as the source states them. CPSC's FAQ opens with “There are two distinct requirements concerning lead in children's products:”, then gives one as a total lead content figure for accessible components and the other as a limit for paint and similar surface coatings. This page keeps them apart because the page that publishes them does.
Was the percentage converted into parts per million here?
No. The equality between 0.009 percent and 90 parts per million stands inside CPSC's own parenthesis and is quoted in that form. No unit conversion is performed on this page. Total content and extraction or migration are different measures, and the sources read give no conversion between them, so figures of those two kinds are not compared here either.
Does CPSC say that electroplating carries no lead requirement?
The sentence read says that printing inks that become part of the substrate, electroplating and ceramic glazing do not meet the definition in 16 CFR § 1303.2(b)(1) and are therefore not subject to 16 C.F.R. part 1303. That is a statement about the reach of one part. It is not a statement that a plated surface contains no lead, and the sources read do not settle how the requirements operate together on a given component.
Is the same content figure used for every children's product?
Not according to the page that publishes it. CPSC lists metal components of bicycles and related products at a total lead content limit of 300 ppm, certain aluminum alloy components for certain children's products at up to 300 ppm by petition, and certain electronic components listed at 16 C.F.R. § 1500.88 as either exempt from the 100 ppm limit or subject to a different lead content limit. Those categories are CPSC's own, and none of them is written about jewelry.
Can Elanorya tell whether a piece is plated, glazed or painted?
No. The product line generates images. It identifies no coating, no alloy and no substrate from a photograph, and nothing it produces is evidence about the material of a piece.