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Originally Posted by waited2long
But, if you make modelling clay out of a mixture of safe clays and plastics, the mixing created a new material, so it would need testing.
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I'm not sure about the phthalates, but lead is an element and no amount of mixing is going to introduce it if it wasn't there in one of the initial ingredients.
However, it might be possible that you could start with an ingredient that falls below the lead PPM threshold, but through some chemical process end up with a result that concentrates lead in the final product to result in something that doesn't pass. The same could be possible for phthalates.
In any case, I was thinking more of a very small or home based manufacturer that's just cutting and sewing clothes or doing simple assembly of components, not a larger operation mixing chemicals into new compounds.
However, even a home based business would have to consider everything they use. If, for example, you were cutting and sewing coats, you'd need to consider not just the fabrics, buttons, and zippers, but also any adhesives you used, any cleaning agents you use if you washed the fabrics, inks and dyes used if you printed anything on the clothes, etc. Thinking about the possibilities, I could see how someone writing the rules might want to require a unit test on any finished products.