What LHAMA requires, exactly
- A toxicological review of the formulation by an expert (the manufacturer’s or a licensed toxicologist).
- Warning labels for known chronic hazards (sensitizers, carcinogens, reproductive hazards) with safe-use instructions.
- The "Conforms to ASTM D-4236" statement on the product packaging.
- Records of the review kept on file.
How kit sellers handle mixed materials
A craft kit is a set of art materials plus other components: each art material needs its D-4236 review, and the kit packaging carries the statements. Suppliers of professional materials often have D-4236 documentation available: collect it, verify it names the same product, and file it with the kit certificate.
Questions people ask
Is D-4236 the same as CPC compliance?
No: D-4236 covers chronic-hazard labeling of art materials. Children’s products additionally need CPSIA testing and a CPC. The regimes stack.
Who performs the toxicological review?
The manufacturer or repackager must have the evaluation performed by a certified toxicologist; several labs offer this as a service alongside testing.
What happens without D-4236 labeling?
Selling mislabeled art materials is a federal violation, and marketplaces remove listings when D-4236 claims cannot be substantiated.
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