What the labels on a box of crayons actually mean

In the United States, art materials are subject to federal labeling requirements, and the statement Conforms to ASTM D-4236 is commonly found on their packaging. It tells you that the product has been evaluated and labeled under the applicable requirements, but by itself it does not make one box of crayons better than another. The voluntary AP Seal from ACMI adds information: it identifies art materials evaluated through ACMI's certification program that meet its criteria. The CL Seal is used for products that require cautionary labeling and is not used on children's art materials.

A parent standing in a store may see several statements, symbols and seals on a box of crayons. At first glance, it can be difficult to tell which ones matter. Some markings are connected to federal requirements, while others come from voluntary certification programs. Here is what the most common ones actually mean.

A quick note before we begin: this article describes United States rules and labeling. It explains what the labels mean, and it does not evaluate the safety of any particular product or provide medical advice. Always follow the manufacturer's age recommendations, instructions and warnings. Questions about your child's health are best discussed with a pediatrician or another qualified healthcare professional.

Conforms to ASTM D-4236: what it means

This is one of the most common statements found on art material packaging, and it is easy to misunderstand.

The Labeling of Hazardous Art Materials Act, or LHAMA, was enacted in 1988 and amended the Federal Hazardous Substances Act. Its requirements are reflected in 16 CFR 1500.14. Art materials offered for sale to consumers in the United States must undergo a toxicological assessment for potential chronic health hazards, and that assessment must be reviewed at least every five years. Art materials must also carry an appropriate statement of conformance, such as Conforms to ASTM D-4236, whenever practicable.

The important point is that this statement is not a special award or a premium safety seal. It is part of the regulatory framework for art materials. If a product presents hazards that require warnings, those warnings must appear in the labeling. So when you are comparing two boxes of crayons, the ASTM D-4236 statement alone does not tell you that one is a better choice than the other.

Source: United States Consumer Product Safety Commission, Art Materials guidance.

The AP Seal: a voluntary certification

ACMI, the Art and Creative Materials Institute, is a nonprofit organization rather than a government agency. Its certification program is voluntary, which means an ACMI seal tells you something beyond the basic fact that a product is sold as an art material in the United States.

AP stands for Approved Product. According to ACMI, the AP Seal identifies art materials evaluated in its certification program by a board-certified toxicologist and found to contain no materials in sufficient quantities to be toxic or injurious to humans, including children, or to cause acute or chronic health problems as defined by the applicable standards. ACMI specifically recommends looking for the AP Seal when choosing creative materials for younger children.

What the CL Seal means

CL stands for Cautionary Labeling. The CL Seal identifies art materials that require cautionary labeling for known health risks and that carry information about their proper use. ACMI states that the CL Seal does not appear on children's art materials and that products carrying it should not be given to children in sixth grade or younger. So for a toddler, a product with the CL Seal is not the right choice.

Source: Art and Creative Materials Institute, Materials Safety guidance.

What about the word non-toxic?

The words non-toxic on a package are not the same thing as the ACMI AP Seal. The AP Seal represents certification through a specific ACMI program and a toxicological evaluation under that program, while a stand-alone non-toxic claim on packaging is simply a statement by the manufacturer.

That does not mean a manufacturer using the term non-toxic is making a misleading claim. It simply means that a general statement on a package and a specific third-party certification seal are not the same thing.

Crayon size and choking hazards

Size matters when you are choosing art materials for a toddler, but there is a detail in the United States rules that is worth knowing, because it is often described incorrectly.

Federal small parts rules use a special test cylinder to identify objects that may present a choking, aspiration or ingestion hazard for children under three. The cylinder is approximately 2.25 inches long and 1.25 inches wide. However, writing materials such as crayons, chalk, pencils and pens are specifically exempt from the small parts ban, and that exemption is listed in 16 CFR 1501.3. Paper articles and paint sets appear on the same list of exemptions.

So it would not be correct to say that crayons for toddlers are made thick because thinner ones are prohibited under that rule. Thick crayons are easier for a small hand to hold and leave a broad, visible mark, and that is reason enough to choose them.

For parents, the practical advice is simpler: choose crayons that the manufacturer intends for your child's age, look at whether the size and shape suit small hands, follow the warnings and instructions on the package, and stay nearby while your child is drawing.

Source: United States Code of Federal Regulations, 16 CFR Part 1501.

Lead in paint and surface coatings

Lead in paint and similar surface coatings is regulated separately in the United States. Under 16 CFR Part 1303, paint and similar surface coatings subject to the rule may not contain lead in excess of 0.009 percent, or 90 parts per million. Parents do not need to test for lead themselves in a store: these requirements apply to the products and coatings covered by the regulation.

Source: United States Consumer Product Safety Commission.

Age recommendations on the package

The age recommendation on a box is useful, because it tells you the age group the manufacturer intends the product for.

But two boxes labeled for the same age can still be quite different. The crayons may differ in thickness, length, shape or ease of use. So it helps to look at the product itself as well as at the number on the package, and to read the manufacturer's instructions and warnings.

What to check in the store in thirty seconds

Look for the AP Seal. Its absence does not by itself mean a product is unsafe, but the seal tells you the product went through ACMI certification and a toxicological evaluation.

If you see a CL Seal, that product is not intended for a toddler. ACMI does not use the CL Seal on children's art materials.

Check the manufacturer's age recommendation and read any warnings or special instructions.

Look at the size and shape of the crayons and consider whether they suit your child's stage of development.

And there is one thing no label or certification can replace: at this age a child colors with an adult nearby.