U.S. - Oregon Tightens Chemical Reporting for Children's Products

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Vol. 1503 | 11 Dec 2025

Oregon has tightened Toxic-Free Kids Act reporting, requiring product-level (BNPM) disclosure of high-priority chemicals in children’s products for 2024–2025, with electronic submissions due January 31, 2026, to enhance transparency and hazard communication.

The Oregon Health Authority (OHA) has promulgated updated reporting requirements under the state’s Toxic-Free Kids Act (TFKA), imposing more rigorous transparency obligations on manufacturers of children’s products. These amendments, authorized by House Bill 3043 (2023), signify a substantive shift by moving from generalized chemical reporting to a model demanding precise, product-level disclosure.

The revised rules introduce Brand Name and Product Model (BNPM) reporting for High Priority Chemicals of Concern for Children’s Health (HPCCCHs). This new framework obligates manufacturers to report the presence of listed chemicals not merely by broad product category, but for each distinct branded product model offered for sale within the state. It is necessary to note that this is an additional reporting requirement, which doesn’t supersede, but rather augments existing obligations.

The regulatory timeline now requires comprehensive disclosure for the 2024 and 2025 calendar years. Manufacturers must report all HPCCCHs present at or above de minimis levels in any component of a covered children’s product.

(1) The practical quantification limit for a chemical that is a contaminant is 100 parts per million.

(2) The practical quantification limits for intentionally added chemicals are the limits established in Exhibit A, incorporated by reference: PQL for intentionally added chemicals

All submissions must be filed electronically via the state’s designated High Priority Chemicals Data System (HPCDS) no later than January 31, 2026.

This change is expected to provide supply chain transparency and detailed hazard communication. The updated administrative rules explicitly delineate the full scope of data required for TFKA compliance. Refer to the following link for more information.

For questions, please contact Andrew Loveland (andrew.loveland@intertek.com) and Harini Ramaswamy (harini.ramaswamy@intertek.com).

If you have any questions, please contact:

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Harini Ramaswamy

Technical Manager, Softlines

Harini provides technical and regulatory support on consumer products testing to retailers in North America. She supports global labs, engages with regulatory bodies, industry groups and standards organizations. Harini holds a master’s degree in Design (Apparel Studies) from the University of Minnesota and B. Tech in Apparel Technology from Anna University, Chennai. Her functional apparel design projects presented at the Industrial Fabrics Association International (IFAI) and Techtextil conferences have won her numerous accolades. 

Email:  harini.ramaswamy@intertek.com

Image of Andrew Loveland
Andrew Loveland

Technical Director - Hardlines, Softlines and Toys

Andrew brings over 20 years of experience in the regulatory compliance and technical services industry relating to consumer products. With a background in electrical engineering, he advises on the technical aspects of identification and application of regulatory requirements and appropriate test methods necessary to measure safety, quality, and performance of consumer products. Andrew often advises retailers and suppliers on appropriate actions to effectively manage compliance risks.  

Email:  andrew.loveland@intertek.com  

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