Natural or synthetic textiles are now exempt from lead testing, therefore the parts of the diaper that need to be tested for lead fall to the snaps and elastic if it is visible, as long as you are not making diapers using fabrics with a waterproof finish or PUL.

While there is no final rule on the definition of a “child care article” it is smart to proceed as though diapers will fall into this category. Phthalate testing would therefore be required due to certain materials used to construct the diaper.

Here is a chart pulled together by Wacky Hermit that details commonly used diaper making materials, and their exemption status. This chart assumes that a diaper will be defined by the CPSC as a “child care article.”

* If these materials are inaccessible (i.e. hidden inside the diaper where no one can touch them), they do not have to be tested for lead.
** Snaps made of certain plastics (polyethylene or polypropylene) do not need to be tested for phthalates.
*** Paints are held to a smaller lead content standard (90 ppm lead) than the underlying metal.

For additional information on diapers and the CPSIA,  refer to the Real Diaper IndustryAssociation which is helping its members take a proactive response to the CPSIA.

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