LHAMA

The Labeling of Hazardous Art Materials Act (LHAMA) requires all art materials to be evaluated for chronic health hazards. Materials posing such risks must have appropriate warning labels. This law applies to all art materials, not just those for children. Under U.S. Consumer Product Safety Commission (CPSC) regulations (16 CFR §1500.14(b)(8)), art materials must undergo LHAMA assessment and labeling in accordance with ASTM D4236.

TRA (Toxicological Risk Assessment)

TRA is a scientific review of a product formulation to assess health risks under normal or foreseeable use—specifically, the potential for acute and chronic toxicity, irritation, or sensitization. Our qualified toxicologists evaluate:

• The hazards of individual ingredients
• Potential interactions among components
• Expected consumer use

Applicable Products

• Crayons, colored pencils, chalk
• Inks, paints (watercolor, acrylic, oil, etc.)
• Glues and adhesives
• Canvases and surface coating materials
• Coloring books, model-making kits
• Other art, craft, or hobby materials (including sets)

Regulatory Basis

United States: CPSC LHAMA (16 CFR 1500.14(b)(8)) + ASTM D4236

European Union: REACH, CLP Regulation, Toy Safety Directive (if applicable)

Canada: Canada Consumer Product Safety Act (CCPSA)

Others: California Proposition 65 (warning requirements), e-commerce platform compliance policies (e.g., Amazon, Temu)

Our Services

1. LHAMA Label Review

• Chronic hazard evaluation by certified toxicologists
• Preparation of ASTM D4236-compliant statements and warning labels (multilingual support available)
• Ensuring labels are traceable, legible, and clearly visible

2. Toxicological Risk Assessment (TRA)

• Ingredient hazard analysis (including SVHC screening)
• Evaluation of potential interactions within the formulation
• Risk determination under normal and reasonably foreseeable misuse conditions
• Exposure scenario analysis and reporting (aligned with latest EU/US requirements)

3. Compliance Consulting & Training

• Interpretation of market-specific regulatory requirements
• Recommendations for internal compliance process optimization

4. Testing & Documentation Review

• Heavy metals testing (Pb, Cd, Hg, Cr⁶⁺, etc.)
• MSDS/SDS review and updating
• Ingredient list verification (chemical name, CAS number, EC number)

Information Required from Clients

• Manufacturer/distributor name and full address (no P.O. Box)
• Contact details (phone, email)
• Target sales countries/regions
• Product name and physical form (solid/liquid/powder/granules)
• Net content per package (in g or kg)
• Recommended age group and intended use
• Suggested amount per use
• Heavy metals test report
• MSDS/SDS for both finished product and raw materials
• Complete ingredient list (chemical name + CAS number + EC number)
• One representative sample for each product model

Why Choose CIRS Testing?

• Global Network: Laboratories in China, plus local offices in Ireland and the U.S., provide localized support
• Expert Team: Certified toxicologists and regulatory specialists involved throughout the process
• Proven Experience: Serving thousands of companies since 2008 across stationery, art supplies, toys, and more
• Efficient & Cost-Effective: Customized solutions to meet multi-jurisdictional requirements quickly

If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.