On June 14, 2025, the state of Minnesota officially enacted HF 4, making significant revisions to Chapter 325E.3892 of the 2024 Minnesota Statutes concerning lead (Pb) and cadmium (Cd) content in consumer products. The new regulations take immediate effect, primarily involving adjustments to controlled product categories and the addition of new exemptions.
I. Scope of Regulated Products
The bill specifies that the following products and their components must comply with lead and cadmium content limits:
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- Jewelry, toys, cosmetics, and personal care products
- Puzzles/board games, playground equipment, outdoor sports gear
- School supplies (excluding fountain pens and mechanical pencils)
- Kitchenware (pots, pans, food containers, etc.)
- Arts and crafts materials (children’s chalk/crayons/paints, excluding professional artist materials)
- Apparel, footwear, accessories, keys, and keychains
- Others: Fidget spinners, party supplies, etc.
Note: “Pastels” refer specifically to crayon-like products made from pigment powder bound with resin.
II. Content Limits
The import, manufacture, or sale of any regulated product is prohibited if it contains:
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- Lead > 90 ppm (0.009%)
- Cadmium > 75 ppm (0.0075%)
III. Exemptions
The following cases are exempt from the above limits:
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- Lead/cadmium-containing products already regulated by federal law;
- Products with lead-containing internal solder (must meet):
- Distribution within the state must cease after July 1, 2028;
- Manufacturers must submit biennial reports on lead phase-out progress;
- Key products:
- Lead-containing keys circulated before July 1, 2028;
- Keys circulated after 2028 with lead content ≤1.5%;
- Cast iron/steel cookware:
- Cadmium is present only in non-food-contact enamel layers;
- Lead content complies with specified limits.
Recommendation: Relevant businesses should promptly verify product compliance to avoid trade risks. For compliance support, consult professional advisory services.
