I emailed Joel Recht
Director, Chemistry Division - Laboratory Sciences
U.S. Consumer Product Safety Commission
this is the response I got from him
Can XRF technology be used to support general conformity certification as to lead paint or lead content limits?
Yes. Where third-party testing by an accredited laboratory is required as the basis for certification, that testing cannot be based on XRF technology at this time; however, XRF testing, either by a manufacturer or by a laboratory, may serve as the basis for general conformity certification. Manufacturers are cautioned, however, to be careful in their use of XRF for this purpose given the difficulties in screening for lead in paint with that technology.
Note that the timeline for what can and can’t be treated that way for your handmade products, consider what rules apply to what product types (handmade or not). For certain items such as painted children’s products and children’s metal jewelry, as well as for certain products that may pose a small parts/choking hazard to young children, cribs, etc., third party certification by an accredited laboratory is either already required for newly manufactured goods (such as for paints), or will soon be required (such as for lead in children’s metal jewelry). Other provisions of the CPSIA, such as lead in other materials (like plastic, glass, textiles, etc.) do not yet require 3rd party certification and won’t for at least several months.
A timeline for this sort of thing is on the CPSIA web page on our public website. Please keep an eye on our website, as we continue to publish new information. Given the number of rules going into effect at the moment, there are many new items going up on that site all the time, and some may address your issues.
