Total Lead Content – U.S. Consumer Product Safety Improvement Act of 2008 (CPSIA), Title I,
Section 101
PASS
Total Lead Content in Toys and Child Care Articles – Client’s Request to Test According to the
Reformulation Level(s) Set forth in the Consent Decrees of Similar Products (Court Case No.:
PASS
Alameda Superior Court RG08378050 / San Francisco Superior Court 07-462991)
Total Heavy Metal Screening in Similar Surface Coating Materials and Toys Substrate Materials –
Soluble Heavy Metals Content in Similar Surface Coating Materials and Toys Substrate Materials
– ASTM F963-17 Section 4.3.5.1(2) & 4.3.5.2(2)(b)
Phthalates Content – 16CFR part 1307, amended U.S. Consumer Product Safety Improvement
Act of 2008 (CPSIA), Title I, Section 108
PASS
PASS
PASS
Phthalates Content – California Assembly Bill Law No. 1108PASS
Phthalates Content in Toys and Childcare Articles – Client’s Request to Test According to the
Reformulation Level(s) Set forth in the Consent Decrees of Similar Products (Court Case No.:
Sacramento Superior Court 07AS04683 / Alameda Superior Court BG07350969 / RG08367601 /
RG07351032 / RG08378050)
Heavy Metals Content – Canada Consumer Product Safety Act – Toys Regulations, SOR/201117 with Amendment SOR/2016-195, Item 23
Total Lead Content – Canada Consumer Product Safety Act – Surface Coating Materials
Regulation (SOR/2016-193)
Total Lead Content – Canada Consumer Product Safety Act – Consumer Products Containing
Lead Regulations (SOR/2018-83)
Total Lead Content in Halloween Costume, Halloween Costume accessories, Halloween Games
and Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the
Consent Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
Cadmium Content in Halloween Costume, Halloween Costume accessories, Halloween Games
and Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the
Consent Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
Total Arsenic Content in Halloween Costume, Halloween Costume Accessories, Halloween
Games and Decoration – Client’s Request to Test According to the Reformulation Level(s) Set
forth in the Consent Decrees of Similar Products (Court Case No.: Alameda Superior Court
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TEST REPORT
REPORT NUMBER:63322-010047PAGE:Page 3 of 25
HG12633575)
Phthalate Content in Halloween Costume, Halloween Costume accessories, Halloween Games
and Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the
Consent Decrees of Similar Products (Court Case no.:Alameda Superior Court HG12633575)
Formaldehyde Content in Halloween Costume, Halloween Costume accessories, Halloween
Games and Decoration – Client’s Request to Test According to the Reformulation Level(s) Set
forth in the Consent Decrees of Similar Products (Court Case No.: Alameda Superior Court
HG12633575)
Remark:
1. As no final packaging was submitted, the labeling review was not conducted in this report.
Sequence Test After Preliminary TrialSequence Test After Preliminary Trial
No.Burning Time
1.
2.
3.
4.
5.
Avg: sec. with specimen(s)Avg: sec. with specimen(s)
6
7.
8.
9.
10.
Avg: sec. with specimen(s)Avg: sec. with specimen(s)
Original State
:
Burning Time
(sec.)
/
(sec.)
/
/
/
/
/
//
//
//
//
//
Burn Code
SF poi#
SF poi
Burn CodeNo.Burning Time
SF poi1.
SF poi2.
SF poi3.
SF poi4.
SF poi5.
Refurbishment State
(After One Laundering)
Length
Against
Nap
Burning Time
(sec.)
:
With Nap:/
(sec.)
6
7.
8.
9.
10.
Burn Code
/
/
/
/
/
/
SF poi#
SF poi
Burn Code
SF poi
SF poi
SF poi
SF poi
SF poi
//
//
//
//
//
REQUIREMENT
(1) The flame spread
time for textile
products with a
raised fibre surface
that exhibits ignition
or fusion of its base
fibres must be
greater than 4
seconds.
(2) The flame
spread time for
bedding without a
raised fiber surface,
or bedding with a
raised fibre surface
that exhibits ignition
or fusion of its base
fibres, must be
greater than 7
seconds.
FAIL
Explanation Of Flammability Results:
Raised Fiber Fabric
SF ucSurface Flash, Under Stop Thread, But Does Not Break Thread (No Time)
SF pwSurface Flash, Part Way. Does Not Break Thread (No Time)
SF poiSurface Flash, At Point Of Impingement Only (No Time); Equivalent To “DNI” For Plain Surface Fabrics.)
0.0 Sec (BB)Actual Burn Time Measured and Recorded By The Timing Device in 0.0 seconds
0.0 SFTime (Sec), Surface Flash Only. No Damage To The Base Fabric.
0.0 SFBB
0.0 SFBBpoiTime (Sec), Surface Flash Base Burn Starting At The Point Of Impingement.
# The burning direction in sequence test is reference to the fastest burning direction found in preliminary trial test.
Sequence Test After Preliminary TrialSequence Test After Preliminary Trial
No.Burning Time
1.
2.
3.
4.
5.
Avg: sec. with specimen(s)Avg: sec. with specimen(s)
6
7.
8.
9.
10.
Avg: sec. with specimen(s)Avg: sec. with specimen(s)
Original State
(sec.)
:
/
(sec.)
/
/
/
/
/
//
//
//
//
//
Burn CodeLengthBurning Time
Burn CodeNo.Burning Time
SF poi#
SF poi
SF poi1.
SF poi2.
SF poi3.
SF poi4.
SF poi5.
Against
With Nap:/
6
7.
8.
9.
10.
Nap
Refurbishment State
(After One Laundering)
(sec.)
:
/
(sec.)
/
/
/
/
/
//
//
//
//
//
Burn Code
SF poi#
SF poi
Burn Code
SF poi
SF poi
SF poi
SF poi
SF poi
REQUIREMENT
(1) The flame spread
time for textile
products with a
raised fibre surface
that exhibits ignition
or fusion of its base
fibres must be
greater than 4
seconds.
(2) The flame
spread time for
bedding without a
raised fiber surface,
or bedding with a
raised fibre surface
that exhibits ignition
or fusion of its base
fibres, must be
greater than 7
seconds.
FAIL
Explanation Of Flammability Results:
Raised Fiber Fabric
SF ucSurface Flash, Under Stop Thread, But Does Not Break Thread (No Time)
SF pwSurface Flash, Part Way. Does Not Break Thread (No Time)
SF poiSurface Flash, At Point Of Impingement Only (No Time); Equivalent To “DNI” For Plain Surface Fabrics.)
0.0 Sec (BB)Actual Burn Time Measured and Recorded By The Timing Device in 0.0 seconds
0.0 SFTime (Sec), Surface Flash Only. No Damage To The Base Fabric.
0.0 SFBB
0.0 SFBBpoiTime (Sec), Surface Flash Base Burn Starting At The Point Of Impingement.
# The burning direction in sequence test is reference to the fastest burning direction found in preliminary trial test.
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TEST REPORT
A
Light up treat bag
REPORT NUMBER:63322-010047PAGE:Page 12 of 25
COMPONENT BREAKDOWN LIST:
Test ItemComponent Description
A1Black coating ( On label )
A2White fabric ( Excluding coating ) ( Label )
A3Orange fabric ( Body )
A4Black / white embroidery ( Body )
A5Orange embroidery ( Body )
A6Orange fabric with black / white / orange embroidery ( Body )
TEST RESULT:
6.Total Lead Content – U.S. Consumer Product Safety Improvement Act of 2008 (CPSIA), Title I, Section 101
Test Item
A1
Accessibility
(Remark 1)
Accessible as
received
Classification
Paint or similar surface
coating
Total Lead (Pb) (ppm)
ResultLimit
Conclusion
<1090PASS
Method:
1) Lead in paint and other similar surface coatings:
The test is conducted according to the US CPSC Standard Operating Procedure for Determining Lead (Pb) in
Paint and Other Similar Surface Coatings, February 25, 2011 (CPSC-CH-E1003-09.1)
2) Lead in metals:
The test is conducted according to the US CPSC Standard Operating Procedure for Determining Total Lead (Pb)
in Children’s Metal Products (Including Children’s Metal Jewelry), November 15, 2012 (CPSC-CH-E1001-08.3)
3) Lead in other non-metal materials including plastics, glass and leather material:
The test is conducted according to the US CPSC Standard Operating Procedure for Determining Total Lead (Pb)
in Non-Metal Children’s Products, November 15, 2012 (CPSC-CH-E1002-08.3)
Remark:
1. The accessibility of the submitted sample is verified according to 16 CFR 1500.87 (e) before and after abuse.
Note:ppm = part per million = mg/kg (milligram per kilogram)
“<” = less than
7.Total Lead Content in Toys and Child Care Articles – Client’s Request to Test According to the
Reformulation Level(s) Set forth in the Consent Decrees of Similar Products (Court Case No.: Alameda
Superior Court RG08378050 / San Francisco Superior Court 07-462991)
Test ItemResult - Total Lead (Pb) (ppm)Conclusion
A1<10
Method:Sample was digested with reference to EPA 3052. The lead content was analyzed by Atomic Absorption
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TEST REPORT
REPORT NUMBER:63322-010047PAGE:Page 13 of 25
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation levels set forth in the Consent Decrees of similar products to the Sample are 90 ppm (Accessible surface coating) / 100 ppm (Accessible substrate) / 200 ppm (Baby bibs). The
reformulation levels set forth in the various Consent Decrees are only the binding requirements for the
defendants named in the case, and by complying with the reformulation requirements, the defendants are
protected from further Proposition 65 violations for the products that are covered in the case. However, the
reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
Note:ppm = part per million
“<” = less than
“>” = more than
NA = Not applicable
8.Total Heavy Metal Screening in Similar Surface Coating Materials and Toys Substrate Materials – ASTM
heavy metals content was determined by Inductively Coupled Argon Plasma Spectrometer / Inductively
Coupled Plasma Mass Spectrometer.
Remark: 1. All the reported results are adjusted analytical results with the analytical correction shown in the
following
table.
ElementSbAsBaCdCrPbHgSe
Analytical correction (%)6060303030305060
2. The accessibility of the submitted sample is verified according to ASTM F963-17 before and after abuse.
3. The received sample(s) contained component(s) of less than 10mg on one single sample, therefore
such component(s) was not tested for soluble heavy metals content as specified in clause 8.3.3.6 (2) /
8.3.5.3 (2) of this standard.
Note:mg/kg = milligram per kilogram
mg = milligram
“<” = less than
10. Phthalates Content – 16CFR part 1307, amended U.S. Consumer Product Safety Improvement Act of 2008
(CPSIA), Title I, Section 108
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TEST REPORT
REPORT NUMBER:63322-010047PAGE:Page 16 of 25
12. Phthalates Content in Toys and Childcare Articles – Client’s Request to Test According to the
Reformulation Level(s) Set forth in the Consent Decrees of Similar Products (Court Case No.: Sacramento
Superior Court 07AS04683 / Alameda Superior Court BG07350969 / RG08367601 / RG07351032 /
RG08378050)
Method:The test is conducted according to the US CPSC Standard Operation Procedure for Determination of
Phthalates, January 17, 2018 (CPSC-CH-C1001-09.4)
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation level set forth in the Consent Decrees of similar products to the Sample is 0.1% (each).
The reformulation levels set forth in the various Consent Decrees are only the binding requirements for the
defendants named in the case, and by complying with the reformulation requirements, the defendants are
protected from further Proposition 65 violations for the products that are covered in the case. However, the
reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
Note:% = percentage
“<” = less than
“>” = more than
NA = Not applicable
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TEST REPORT
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13. Heavy Metals Content – Canada Consumer Product Safety Act – Toys Regulations, SOR/2011-17 with
Amendment SOR/2016-195, Item 23
Result
Test Items
Total Content (mg/kg)Soluble Content (%)
Conclusion
PbHgBaCdAsSbSe
A1<10<100.001<0.001<0.001<0.001<0.001PASS
Limit90
No
introduced
0.10.10.10.10.1-
Pb = Lead, Hg = Mercury, Ba = Barium, Cd = Cadmium, As = Arsenic, Sb = Antimony, Se = Selenium
Method: Sample was digested with nitric acid for total lead and mercury content.
Sample was extracted with 5% hydrochloric acid for 10 minutes at 20oC according to Canada Consumer
Product Safety Act – Toys Regulations, SOR/2011-17, Item 23(b) for soluble heavy metals content.
The heavy metals content were analyzed by Atomic Absorption Spectrophotometer / Inductively Coupled
Argon Plasma Spectrometer / Inductively Coupled Plasma Mass Spectrometer.
Note:mg/kg = milligram per kilogram
% = percentage
“<” = less than
14. Total Lead Content – Canada Consumer Product Safety Act – Surface Coating Materials Regulation
(SOR/2016-193)
Total Lead (Pb) (mg/kg)
Test Item
Conclusion
ResultLimit
A1<1090PASS
Method: Sample was digested with nitric acid and analyzed by Atomic Absorption Spectrophotometer / Inductively
Coupled Argon Plasma Spectrometer / Inductively Coupled Plasma Mass Spectrometer.
Note:mg/kg = milligram per kilogram
“<” = less than
15. Total Lead Content – Canada Consumer Product Safety Act – Consumer Products Containing Lead
Regulations (SOR/2018-83)
Remark: Not applicable for the submitted sample. No PVC was found on the submitted sample.
17. Total Lead Content in Halloween Costume, Halloween Costume accessories, Halloween Games and
Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the Consent
Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
Test ItemResult - Total Lead (Pb) (ppm)Conclusion
A1<10
PASS
(See Remark)
Method:Sample was digested with reference to EPA 3052. The lead content was analyzed by Atomic Absorption
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation levels set forth in the Consent Decrees of similar products to the Sample are 90 ppm (Surface coating) / 100 ppm (Children’s Substrate) / 300 ppm (Adult’s Substrate). The reformulation
levels set forth in the various Consent Decrees are only the binding requirements for the defendants
named in the case, and by complying with the reformulation requirements, the defendants are protected
from further Proposition 65 violations for the products that are covered in the case. However, the
reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
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REPORT NUMBER:63322-010047PAGE:Page 19 of 25
“>” = more than
NA = Not applicable
18. Cadmium Content in Halloween Costume, Halloween Costume accessories, Halloween Games and
Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the Consent
Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
Test ItemClassification
A1Accessible component<10NT
A2Accessible componentNT<10
A3Accessible componentNT<10
A4Accessible componentNT<10
A5Accessible componentNT<10
Result – Cadmium (Cd) (mg/kg)
TotalExtractable
Conclusion
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
Method:1) Total Cadmium:
Sample was digested with reference to EPA 3052. The cadmium content was analyzed by Atomic
Absorption Spectrophotometer / Inductively Coupled Argon Plasma Spectrometer / Inductively
Coupled Plasma Mass Spectrometer.
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation levels set forth in the Consent Decrees of similar products to the Sample are 300 ppm
(Mounthable component by Digestion method) / 75 ppm (Accessible component by Extractable
method excluding mouthable parts). The reformulation levels set forth in the various Consent Decrees
are only the binding requirements for the defendants named in the case, and by complying with the
reformulation requirements, the defendants are protected from further Proposition 65 violations for the
products that are covered in the case. However, the reformulation levels set forth in the various Consent
Decrees are not necessarily the safe harbor limits. The reformulation levels set in the Consent Decrees
are usually expressed in relative concentration levels (i.e., mg/kg, ppm) while the safe harbor limits identify
a level of exposure to a listed chemical in micrograms per day. Therefore, for businesses that are not
named in the Consent Decrees as defendants, complying with the reformulation levels of Consent
Decrees does not fully protect the businesses from being sued for the possible violation of Proposition 65.
These businesses may still be sued for the possible violation of Proposition 65 and will have the burden of
proving that the listed chemical in their products are under the safe harbor level or that the anticipated
exposure level will not pose a significant risk of cancer or reproductive harm.
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TEST REPORT
REPORT NUMBER:63322-010047PAGE:Page 20 of 25
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
Note:mg/kg = milligram per kilogram
“<” = less than
19. Total Arsenic Content in Halloween Costume, Halloween Costume Accessories, Halloween Games and
Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the Consent
Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
Test Item
A1<5NT
A2NT<5
A3NT<5
A4NT<5
A5NT<5
Method:1) Total Arsenic:
Sample was digested with reference to EPA 3050B, EPA 3051 or EPA 3052. The arsenic content was
analyzed by Atomic Absorption Spectrophotometer / Inductively Coupled Argon Plasma Spectrometer /
Inductively Coupled Plasma Mass Spectrometer.
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation level set forth in the Consent Decrees of similar products to the Sample is 25 ppm. The
reformulation levels set forth in the various Consent Decrees are only the binding requirements for the
defendants named in the case, and by complying with the reformulation requirements, the defendants are
protected from further Proposition 65 violations for the products that are covered in the case. However, the
reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
AMERICA Norwood (MA) EUROPEAugsburg Hamburg Istanbul
Conclusion
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
PASS
(See Remark)
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REPORT NUMBER:63322-010047PAGE:Page 21 of 25
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
Note:ppm = part per million
“<” = less than
“>” = more than
20. Phthalate Content in Halloween Costume, Halloween Costume accessories, Halloween Games and
Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the Consent
Decrees of Similar Products (Court Case no.:Alameda Superior Court HG12633575)
Method:Sample was extracted with organic solvent and analyzed by Gas Chromatograph Mass Spectrometer /
Liquid Chromatograph Mass Spectrometer.
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation level set forth in the Consent Decrees of similar products to the Sample is 0.1% (each).
The reformulation levels set forth in the various Consent Decrees are only the binding requirements for the
defendants named in the case, and by complying with the reformulation requirements, the defendants are
protected from further Proposition 65 violations for the products that are covered in the case. However, the
reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
AMERICA Norwood (MA) EUROPEAugsburg Hamburg Istanbul
Conclusion
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REPORT NUMBER:63322-010047PAGE:Page 22 of 25
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
Note:% = percentage
“<” = less than
NA = Not applicable
21. Formaldehyde Content in Halloween Costume, Halloween Costume accessories, Halloween Games and
Decoration – Client’s Request to Test According to the Reformulation Level(s) Set forth in the Consent
Decrees of Similar Products (Court Case No.: Alameda Superior Court HG12633575)
A. Free and Hydrolyzed Formaldehyde in Textiles
Test Item
A2+A3<16
A6<16
Formaldehyde (mg/kg)
Result
Conclusion
PASS
(See Remark)
PASS
(See Remark)
Method:ISO 14184-1:2011
Note:1. Further quantitative analysis of formaldehyde is recommended when either positive or inconclusive
result is reported by screening test.
2. The requirement of formaldehyde is summarized as below:
I) Accessible fabric of covered product for children under 3 years old shall not more than 20mg/kg.
II) Accessible fabric of covered product for children 3 years old and up, and/or adult shall not more than
75mg/kg
Remark: Proposition 65 requires businesses to warn Californians about exposures to certain listed chemicals
known to cause cancer, birth defects, or other reproductive harm. If a business exposes a Californian to a
listed chemical without providing a warning, then the business may be sued for the possible violation of
Proposition 65. The business will then have the burden of proving that the listed chemical in the product is
under the safe harbor limit or that the anticipated exposure level will not pose a significant risk of cancer or
reproductive harm.
The reformulation levels set forth in the Consent Decrees of similar products to the Sample are:
I) Accessible fabric of covered product for children under 3 years old shall not more than 20mg/kg;
orII) Accessible fabric of covered product for children 3 years old and up, and/or adult shall not
more
than 75mg/kg
The reformulation levels set forth in the various Consent Decrees are only the binding requirements for the
defendants named in the case, and by complying with the reformulation requirements, the defendants are
protected from further Proposition 65 violations for the products that are covered in the case. However, the
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reformulation levels set forth in the various Consent Decrees are not necessarily the safe harbor limits.
The reformulation levels set in the Consent Decrees are usually expressed in relative concentration levels
(i.e., mg/kg, ppm) while the safe harbor limits identify a level of exposure to a listed chemical in
micrograms per day. Therefore, for businesses that are not named in the Consent Decrees as defendants,
complying with the reformulation levels of Consent Decrees does not fully protect the businesses from
being sued for the possible violation of Proposition 65. These businesses may still be sued for the
possible violation of Proposition 65 and will have the burden of proving that the listed chemical in their
products are under the safe harbor level or that the anticipated exposure level will not pose a significant
risk of cancer or reproductive harm.
If your product contains any amount of a listed chemical, the only way to fully avoid the possibility of the
burden of proving that the listed chemical in your product is under the safe harbor limit or that the
anticipated exposure level will not pose a significant risk of cancer or reproductive harm is to provide a
warning about the exposures to the listed chemical known to cause cancer, birth defects, or other
reproductive harm. Please consult MTS for more details regarding the different options of labeling and the
mechanics of labeling.
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****End of Test Report****
NOTE:
Test uncertainties not reported are at client’s disposal, for those in which it is possible to evaluate or estimate the test uncertainty.
The statement of conformity is based on a 95% coverage probability for the expanded uncertainty of the measured result (guard
band):
Rule 1:
For any requirement state to be “Maximum”
PASS - The measured result is below a specification limit minus guard band.
INCONCLUSIVE - The measured result is inside the guard band and below the specification limit and the measured result is above
the specification limit but below the specification limit added to the guard band.
FAIL - The measured result is above a specification limit added to the guard band.
DATA – There is no specification limit required which is not possible to state the conformity.
Rule 2:
For any requirement state to be “Minimum”
PASS - The measured result is above a specification limit plus guard band.
INCONCLUSIVE- The measured result is inside the guard band and above the specification limit and the measured result is below
the specification limit but above the specification limit added to the guard band.
FAIL - The measured result is below a specification limit minus guard band.
DATA – There is no specification limit required which is not possible to state the conformity.
Rule 3:
For any requirement state to be “a range (Between Upper to Lower specification limit)
PASS - The measured result is within a range of upper and lower acceptance limit.
INCONCLUSIVE- The measured result is inside the guard band at either side of specification limits
FAIL - The measured result is outside a specification limit minus/added to the guard band.
DATA – There is no specification limit required which is not possible to state the conformity.
Rule 4:
For any test based on subjective grading of results by using 9-point scale
PASS - The measured result is above specification limit.
FAIL - The measured result is below a specification limit.
DATA – There is no specification limit required which is not possible to state the conformity.
This test report is governed by the Terms and Conditions, available on request or accessible at https://www.mts-
global.com/en/terms.html.Attention is especially drawn to the limitations of liability, indemnification and jurisdictional provisions
defined therein. This report is issued strictly based on the testing of the samples, products, materials submitted by you to the
laboratory, as described in the “Sample Description” section and tested in the conditions shown in the present report. The test results
in this report refer only to the sample(s) actually tested and do not refer or be deemed to refer to any bulk production from which such
sample(s) may be said to have been obtained. In the event that MTS was requested to survey and test any bulk production quantity of
samples, MTS, in the absence of any contrary written instructions, performed random sampling of bulk production for testing
purposes. Variations in the conditions under which samples are stored, transported, etc., may lead to variations in the test results.
MTS cannot anticipate and shall not be held responsible for variations in test results that may be due to factors beyond MTS’ control,
such as, sample cross-contamination, evaporation of volatile substances due to storage temperature, humidity, etc. This report does
not constitute a recommendation, actual or implied, for any specific course of action. Other than the expressed warranties made in the
Terms and Conditions of the MTS Test Request Form, MTS makes no warranties or representations either express or implied with
respect to this report. In no circumstances whatsoever shall MTS be liable for any consequential, special or incidental damages
arising out of, or in connection with, this report. This document shall not be reproduced unless prior written authorization from MTS
has been attained. Printed copies of this document shall be considered as a copy.