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New Zealand Strengthens Lead Requirements for Paints and Graphic Materials

SafeGuardSHardgoods, Toys and Juvenile ProductsSeptember 03, 2024

SG 137/24

New Zealand’s EPA has strengthened lead requirements in several group standards for paints and graphic materials. The requirements will be implemented in phases, starting September 19, 2024.

In October 2023, New Zealand consulted over its proposal to revise several group standards for aerosols, corrosion inhibitors and surface coatings and colorants, as well as one graphic materials standard (SafeGuardS 155/23).

On August 22, 2024, New Zealand’s Environmental Protection Authority (EPA) issued the Group Standards (Reducing Lead) Amendment Notice 2024 (the Notice) to revise a series of group standards by setting the maximum levels for lead in paints and tightened rules for graphic materials such as crayons, finger paints and felt-tip pens.

The Notice contains several important changes to group standards. It:

  • Revises a series of group standards (Schedule 1, Parts 1 to 5):
    • 16 surface coatings and colorants group standards
    • 8 other surface coatings and colorants group standards
    • 6 aerosol group standards
    • 6 corrosion inhibitors group standards
    • Graphic materials group standard 2020

  • Restricts lead to 90 ppm in paints falling under the Surface Coatings and Colorants Group Standards and Aerosols Group Standards
  • Sets a limit for lead of 90 ppm to the Corrosion Inhibitors Group Standards
  • Specifies the evidence of compliance (test results) and recommendations for lead restrictions in the relevant standards
  • Updates the element migration limits in the Graphic Group Standard to those in EN 71-3:2019+A1:2021
  • Revises references to ‘EN 71-3:2019+A1:2021’ or ‘AS/NZS ISO 8124.3:2021’ in the relevant Group Standards
    • Amends references to EN 71-3:2019+A1:2021 in the Surface Coatings and Colorants Group Standards and Aerosols Group Standards
    • Updates references to AN/NZS ISO 8124.3:2021 in the explanatory note under the Graphic Materials Group Standard

  • Modifies group standards so all graphic materials marketed to children (any person 12 years old or younger) are only covered by the Graphic Materials Group Standard
  • Deletes the notification requirement from the Graphic Materials Group Standard, effective September 19, 2024 (28 days after notification in the Gazette)
  • Mandates the disposal of products or substances by September 1, 2025, if they do not meet the requirements of the amended group standards
  • Revises all Surface Coating and Colorant Group Standards and Aerosols Group Standards by:
    • Extending the restriction on the use of paints that do not meet requirements for toys to cots
    • Requiring the precautionary labeling statement ‘Not suitable for use on children’s toys or cots’ for paints not meeting the lead levels, making them unsuitable for use in toys or cots

There are three important effective dates:

  • September 19, 2024: the notification requirement from the Graphic Materials Group Standard is no longer required (28 days after notification in the Gazette)
  • March 1, 2025: provisions in the Notice on amended standards other than the point above will become effective
  • September 1, 2025: products not meeting the amended standards must be disposed of

Further information on 1) the decision document and a summary of the new rules and 2) the set of group standards that are currently in force can be found in the EPA website.

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