Proposal for  Legal Inspection of Erasers 
 
By the Bur eau of  Standards, Metrology and Inspect ion (BSMI) , Ministry of  Economic Affairs 
 
 
Backgr ound: 
Phthalates are toxic subs tances th at may be found in soft PVC, a type of plastic which is also 
used in the m anufacturing of erasers. Concerns have been raised by consum ers about the hazard 
of children’ s exposure to phthalates by licki ng and chewing erasers. Based on a project 
perform ed by the BSMI on m arketed erasers in  2010, a high phthalates le vel was detected and 
the labels did not show where they were m anufactured. The Bureau of S tandards, Metrolog y and 
Inspection ( BSMI ), after having consulted w ith in teres ted pa rties, in tends to regula te the 
chem ical m aterials and p hysical p erform ance of  erasers, including the prohibition of use of 
phthalates (DBP , BBP , DEHP , DNOP , DINP  and DI DP) (the concentra tion lev el shall be less 
than 0.1%). 
 
 
Proposed date of implementation:   
‧1 July 201 1 
 
Inspection standards:  
CNS 6856 Plastic Erasers 
 
 
Inspection items : 
• Chem ical M aterials Test :  
1. Migration of Certain Elem ents Test: analyses  of the m igration of the elements antim ony 
(Sb), Arsenic (As), Barium  (Ba), Cadm ium (Cd), Chrom ium (Cr), Lend (Pb), Mercury 
(Hg) and Selem ium (Se) for eras ers m aterials will be perform ed. 
2. Determ ination of plastic izer Tes t: level of  phthalates (DBP, BBP, DEHP, DNOP, DINP, 
DIDP) shall not exceed 0 .1% by m ass of the pl asticized m aterial for eras ers m aterials.  
• Physical Pe rformance Test: ha rdness test, transf erence tes t and erasing ca pability te st will be 
perform ed. 
 
 
Products (HS/CCCN codes) cover ed: 
HS/CCCN 3926.10.00.00.3 Office or school supplies, of plastics (inspe ction scope confined to 
Erasers ) 
HS/CCCN 4016.92.00.00.3 Erasers. 
 
Conformity  Assessment Procedur es 
Applicable C onform ity Assess ment Procedures for toy s listed in the Table are a s follows: Monitoring 
Inspection and Monitoring Inspectio n of Products from  Premises with Registered Managem ent 
System s or Registration of Product Certif ication (RPC) Schem e (Module II + III)  
 
Monitoring Inspection  
Further inform ation on the procedures is  availab le on the BS MI web site at  
http://www .bsm i.gov.tw/wSite/ct? xItem =4460&c tNode=81 1&mp=2
 1Registration of Product Certification (RPC) Schem e 
Under this procedure, m anufacturers m ust have  their products type-tested by the BSMI or 
designated testing laboratories  recognized by the BSMI (M odule II) before applying for 
regis tration of  their  products. M anufacturers  or importers will a lso be required to  ensure  by 
declaration (Module III) that all products made  at their m anufacturing facilities are in 
confor mity with the pro totypes submitte d for typ e testing in Module II.  
Products w ill be allow ed to use the Commod ity Inspection Mark, th e letter “R” and the  
identification num ber given by the BSMI, af ter they a re certified and registered with the BSMI. 
These products can then pass through customs direc tly without any further inspection.  The 
application fee and annual fee for RP C is NT$ 5,000 for each type of product,  and a RPC  
certificate is  valid for th ree years. 
 
Further inform ation on this procedure is al so available on the BSMI web site at  
http://www .bsm i.gov.tw/wSite/ct? xItem =4452&c tNode=81 1&mp=2
 
Locations to apply for  Monitoring  Inspection or Registration of Pr oduct Certification: 
‧The BSMI or its b ranches.  
 
 
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