For now, you’ll have to go to the individual manufacturers to see if they can provide certification that their products have been tested by a 3rd-party lab.

Tom’s blog (linked above) has contact info for some of the larger finish manufacturers.

LP

Sorry. Personally, I’m not comfortable going any further than “might.” (Especially in the realm of legal advice. I can’t emphasize enough that I Am Not A Lawyer.) Unfortunately, the entire thing has been a quagmire of vague, difficult-to-parse, or cautiously worded statements. Not that they’re not trying. The vibe I get from talking to the CPSC is that they were handed a very broad, very undefined law. Because they are an enforcing agency rather than a legislative body, they are doing their best to clarify the law, repeatedly seeking advice from Congress and making allowances as best they can within the letter of that law. Unfortunately, there’s no telling how long the “clarification” stage may last before enforcement begins in earnest (parts keep getting continuously bumped) so …

You “might” be off the hook for expensive up-front 3rd-party testing, but you certainly won’t be off the hook if your product is found after-the-fact to have over-the-limit lead content in it.

While you might feel that you’re off the hook if your finish manufacturer supplies testing data, you also might have used a screw, a dollop of glue, a hinge, etc. Can you demonstrate that these components have been lab-tested as well?

At the moment, the component testing stuff is an interim policy, meaning it might be changed in the future. (Or it might be adopted as the permanent solution, who knows?)

You might be off the hook if you’re giving the items away charitably. But you might not. Some interpret the law as applying only to interstate commerce. Thus charitable donations are excepted. Some interpret the law to mean all manufactured products fall under its umbrella. I’ve even heard reports allegedly quoting different employees/officers of the CPSC which–you guessed it–they disagree with each other.

A mighty lot of mights, I know.

LP