Safe Creative Play: Navigating Compliance with LHAMA Regulations for Art Materials

First published::
March 2025

Creative play is not just fun; it’s a vital part of childhood development that stimulates imagination and fosters expression. As parents and educators encourage artistic exploration, concerns about safety in art materials become increasingly significant.

The potential health risks associated with some supplies make it essential for manufacturers and retailers to ensure compliance with the Labeling of Hazardous Art Materials Act (LHAMA).

In this article, we will explore the LHAMA compliance processes and its labelling requirements.

Overview of LHAMA

The Labeling of Hazardous Art Materials Act (LHAMA) is a significant legislation in the United States designed to protect consumers, especially young artists, from potentially dangerous materials. Under LHAMA, manufacturers are required to evaluate their art materials for potential hazards and provide appropriate warnings.

The LHAMA requires that arts and craft materials be tested for potential chronic hazards by certified toxicologists in accordance with the provisions of ASTM D-4236, and appropriate warning labels must be prominently displayed on the packaging.

Manufacturers must conduct toxicological assessments of their art products at least every five years, keeping abreast of any new health and safety research relevant to their materials.

The LHAMA requirements are detailed in these legislative and regulatory sources:

• Labeling of Hazardous Art Materials Act (LHAMA)
• Federal Hazardous Substances Act (FHSA)
• 16 CFR Part 1500 - Hazardous Substances and Articles
• ASTM D-4236

Complying with the LHAMA is mandatory for art suppliers. Failure to comply can lead to severe consequences, including product recalls, legal liabilities, and company reputation damage.

Scope of LHAMA

It’s essential to understand which products fall under LHAMA, as not all art materials are subjected to the same requirements.

The term “arts and craft materials” in LHAMA refers to any product or substance marketed or sold as usable for any phase of the creation of visual or graphic arts and packaged for use by consumers of all ages in the United States.

Art materials that typically fall within this category include:

• Adhesives, putties, and glues
• Brushes, frames, and canvas
• Ceramics, clays, and other modelling compounds
• Coloured pencils, markers, crayons, and chalks
• Paints and inks

Complying with LHAMA

Below is a brief overview of LHAMA guidelines for art supplies:

• Submit the formulation of the art material for a Chronic Hazard Review
• Verify that the product, its packaging, or its accompanying materials include a compliance statement with ASTM D-4236
• Affix appropriate labels and warnings where necessary.
• Submit a list of products that require hazard warning labels to the U.S. Consumer Product Safety Commission (CPSC)
• Provide documentation describing how the manufacturer determines if the art material might produce chronic adverse health effects to the CPSC

If the art materials or art material products are intended for children aged 12 years or younger, then Consumer Product Safety Improvement Act (CPSIA) requirements should be followed. CPSIA requirements include:

• CPSC-accepted laboratory testing
• Affixing a tracking label on the product
• Drafting a Children’s Product Certificate (CPC)

LHAMA Chronic Hazard Review

Materials for art and craft intended for sale in the U.S. must be subjected to a LHAMA chronic hazard assessment by a certified toxicologist at least once every five years. This review is also required whenever new significant hazard information emerges or when products are reformulated.

The review will specifically consider:

• Current chemical composition of the art material submitted
• Scientific knowledge of the chronic toxic potential of the individual components and the total formulation
• Specific physical and chemical form of the art material product, bioavailability, concentration, and the amount of each potentially chronic toxic component found in the formulation
• Reasonably foreseeable uses of the art material product
• Potential for known synergism and antagonisms among the various components of the formulation.
• Potential chronic adverse health effects of decomposition or combustion products
• Opinions of various regulatory agencies and scientific bodies, on the potential chronic adverse health effects of the various components of the formulation

List of CPSC-accepted Testing Laboratories

The assessment of LHAMA chronic hazard review must be conducted by a certified toxicologist.

The CPSC provides a list of toxicologists on its site.

For art materials marketed for children aged 12 years or younger, CPSIA requirements must be adhered to. Approved laboratories can be found through the CPSC. You can view the list of Eurofins laboratories that are accepted as CPSC testing laboratories.

Labelling Requirements for LHAMA

If the arts and crafts materials are determined to cause chronic health damage, the packaging must contain the following:

• Health warning
• Instructions for safe handling
• Precautionary statement
• Conformance statement to D-4236
• Source of information
• Name and US address of the producer or repackager
• A U.S. phone number available for inquiries regarding potential dangers and risks
• A declaration regarding the inappropriateness of the art supplies for children's use (if required)

How can Eurofins Softlines & Hardlines Help in LHAMA Compliance?

LHAMA requires that art materials undergo a chronic hazard review by a certified toxicologist. If the art materials are for children aged 12 or younger, they must be tested by a CPSC-accepted lab.

Within the Eurofins Softlines & Hardlines network, we have a certified toxicologist based in our laboratory in the U.S. Additionally, we have several laboratories located in different countries that are CPSC-accepted, assisting buyers and suppliers of arts and crafts materials in ensuring compliance with LHAMA.

Contact us to ensure LHAMA compliance now!