Reporting Rule Guidance

These documents are intended to provide guidance on implementation of the Children's Safe Product Act Reporting Rule (WAC 173-334).

Last updated April 5, 2012

Product categories

The rule requires reporting by product category. The purpose of this guidance to clarify what is meant by the term "product category" in the context of the rule. The definition of “children’s product” established in the law and rule, in combination with an existing product categorization system, will be used to establish the products that are subject to reporting.

Product components

The rule requires reporting by product component. The purpose of this guidance to clarify what is meant by the term "product component" in the context of the rule.

Reporting responsibility

This guidance is meant to clarify the hierarchy for determining which entity meeting the statutory definition of “manufacturer” the department will hold primarily responsible for ensuring that reporting requirements are satisfied.

Due diligence

The purpose of this guidance is to provide clarification on what Ecology will look for in the event that the agency must evaluate the sufficiency of manufacturer efforts to minimize the presence of contaminants in their products (WAC 173-334-080(1)(c)).

Practical Quantification Limit (PQL)

This guidance is provided to indicate projected practical quantification limits (PQLs) for products.

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Complying with the Reporting Rule - A Step-by-Step Guide for Manufacturers

1. Determine if any of the products you manufacture occur in the GS1 "bricks" listed in Ecology's guidance on product categories.
2. Determine if you are the party responsible for reporting using Ecology's guidance on reporting responsibility.
3. Determine when your reports are due based on the table in WAC 173-334-110. The table lists the number of months after the effective date of the rule (August 2011) that your reports are due. Where you fall in the table is based on:
   • Your gross sales reported on your last federal tax return.
   • Which tier or tiers your products fall into.

You or the party reporting on your behalf will need to use the web form provided by Ecology. The party responsible for reporting will be held accountable for both the accuracy and timeliness of the required reports, irrespective of who actually enters the data.

If Ecology finds a discrepancy between the reported data and the results from our laboratory analysis of products, Ecology will make a good faith effort to contact the party responsible for reporting to give them an opportunity to provide an explanation before taking any further action.