Authorized By: Scott Crump

Sr. Director Global Apparel & Equipment Product Integrity

CSP03216R2.0 CSPIA Implementation
Plan
Approved By: [Name] Martine Mientjes

Effective Date: DD-MMM-YYYY Revision # 2.0 Revision Date: 29-NOV-2016 Owner: {Name] Logan LaRossa

Consumer Product Safety Improvement Act (CPSIA) Contact Info

Lst-CPSIA@nike.com
Implementation Guide for Nike & Affiliates— February, 2012 Update Website
www.coc-insight.com

What is it? What is Changing? Beginning January 1, 2012 (date of manufacture)

Bill HR 4040 signed into law August 14, 2008 by the US Congress—with several final
rules and guidelines issued between 2008 and 2011. Total Lead Content Testing:
The CPSC’s stay of enforcement on Total Lead Testing expires on 12/31/2011 at which time manufacturers must begin certifying compliance with Total Lead Content requirements for
Purpose:
regulated products on their CPSIA Certificates of Compliance.
To establish consumer product safety standards and other safety requirements for
children’s products and to reauthorize and modernize the Consumer Product Exclusions: Textiles are excluded from this Mandatory 3rd Party Testing requirement.
Safety Commission (CPSC) in the United States.
Scope: Examples of what needs to be tested: Hard Trims, Plastics, Screen Prints, Synthetic Leather, Leather, Vinyl, Glues, Foam, Metal, Hard Goods.
Regulated Products: All children’s products (any consumer product primarily
designed or intended for children 12 years old and younger) and any other product Flammability Testing Children’s Apparel
imported into or distributed in the United State that is subject to a consumer Statements of compliance for flammability of children’s apparel must be based on third party testing. Third party testing for children’s product is already mandatory under Nike’s
product safety rule under the Consumer Product Safety Improvement Act and: flammability testing program.
• FFA: Flammable Fabrics Act For adults apparel, statements of compliance for Flammability continue to be based on the company’s “reasonable testing program”.
• CPSA: Consumer Product Safety Act
• FHSA: Federal Hazardous Substances Act Mandatory Third Party Testing may be applied to Components rather than Finished Products:
What this means :
• Factories can now request proof of component testing to CPSIA requirements from the item Vendor rather than conducting a test of a Finished Product. * A passing RSL or CPSIA
specific test report from an Item Vendor is an acceptable means to satisfy CPSIA component testing.
Immediate Action: • Finished Product Certificates of Conformity can be based on these component tests.
• Frequency of re-certification of styles is every 12 months or anytime there is a change to the finished product or components
Organizational Awareness:
• If the vendor is not able to supply proof of CPSIA or RSL testing to the factory, the factory must send the component to a CPSIA accredited lab for testing according to the current
Ensure all critical team members are aware of these requirements.
process.
Notify Factories & Vendors of Updates to CPSIA Requirements: Screen Prints: certificates for screen printed styles can be based on RSL testing or CPSIA specific testing of the base inks used in the screen print. The printer must ensure full
All factories and vendors producing Regulated Products or Components for your
division or affiliate brand should be notified as soon as possible of these traceability of the inks used to the finished, printed style.
requirements.

1 CONTROLLED DOCUMENT Nike Confidential Final_CSP03216R1.1_CSPIA Implementation Plan_LLaRossa_29-NOV-2016

 Authorized By: Scott Crump
Sr. Director Global Apparel & Equipment Product Integrity
CSP03216R2.0 CSPIA Implementation
Plan
Approved By: [Name] Martine Mientjes

Effective Date: DD-MMM-YYYY Revision # 2.0 Revision Date: 29-NOV-2016 Owner: {Name] Logan LaRossa

Children’s Products Mandatory 3rd Party Testing Testing Basis Standard Apparel Footwear Equipment

Lead in Paints and Coatings <90 ppm* Component OR

16 CFR 1303   
What Stays the Same… Finished Product

Certificates of Compliance (COC): Lead Content by Weight (all components) <90 ppm*
Component OR
**Textiles are excluded from this CPSIA testing requirement but must still 16 CFR 1500.23   
Applies to: Regulated Products sold in the US. Finished Product
meet the Nike RSL requirement.
Responsible Party: Finished goods manufacturer. Flammability of Children’s Sleepwear Nike’s Material
Testing Program
16 CFR 1616 
Based on: Applicable Mandatory 3rd Party Testing*
Note: Statements of compliance for Flammability of Adults apparel continue to be Flammability of Wearing Apparel Nike’s Material
Testing Program
16 CFR 1610  
based on the company’s “reasonable testing program”. **for Equipment category, this applies to socks.

Phthalate Total Content (DEHP, DBP, BBP) <1000 ppm **applies to items Component OR
System: Online Nike, Inc. CPSIA Database, www.coc-insight.com classified as “toys” Finished Product
HR 4040 

*Mandatory Third Party Testing: Small Parts—applies to products intended for <36 mos., excluding apparel
Finished Product 16 CFR 1501 
and footwear.
Applies to Regulated Products subject to a product safety rule as listed in the table.
Drawstrings Finished Product Self-
Evaluation
ASTM F-1816  
Testing must be conducted at CPSC accredited labs.
CPSC Accredited Labs: https://www.cpsc.gov/cgi-bin/labsearch/ Sharp Points & Edges—applies to products intended for children 8 yrs. Finished Product Self-
and under. Evaluation
16 CFR 1500.48--.49   

Toys Component OR
Finished Product
ASTM F963-08   

*90 mg/kg lead (Pb) in all materials is based upon the Nike RSL requirement and supersedes the phased in higher limits of CPSIA.(www.nikeresponsibility.com/rsl).

Revision Date Revision# Description of changes Revised by Approved by

03-OCT-2014 R1.1 Revision history unavailable began R1.1 revision Annette Shabat Shelly Silvana Reagan
number. Standardized headers and footers + added
revision history
29-NOV-2016 R2.0 Updated language around re-certification frequency Logan LaRossa Martine Mientjes
from once per 3 months to once per 12 months (or if
something changes) as per the legal requirement.
Updated weblink to CPSC accredited labs as the old link
was no longer valid.
Updated document owner from Kate Horspool to
Logan LaRossa

2 CONTROLLED DOCUMENT Nike Confidential Final_CSP03216R1.1_CSPIA Implementation Plan_LLaRossa_29-NOV-2016