Q: Do zipper pulls need phthalate testing under CPSIA?
The federal phthalate rule covers children's toys and child care articles, not apparel as a category, so a zipper on a jacket is usually outside its scope. The question changes when the pull is a moulded plastic shape that a child may mouth, or when the zipper is sold as part of a toy. In that case the eight restricted phthalates are limited to 0.1 percent each by weight.
Testing is by solvent extraction and GC-MS on the plasticiser-containing parts, usually the soft PVC or flexible moulding rather than the metal. Submit a whole pull or a representative cut of the flexible material, and state the colour and hardness. Rigid mouldings with no added plasticiser can often be cleared by a material declaration, but the declaration must name the polymer and confirm that no plasticiser was added. Refer to the standard text for extraction conditions.
A pass means each restricted phthalate is below 0.1 percent in each plasticised material, not the average of the pull. Keep the declaration and the test report together, and review the answer again if the moulding compound or the colour masterbatch changes.