A child’s shoe sold in the United States has to meet two separate lead limits. The material itself, in any part a child can reach, may hold no more than 100 parts per million (ppm) of total lead. Paint and other surface coatings on the shoe may hold no more than 0.009 percent lead, which is 90 ppm. In our archive of 103 footwear recalls, six were recalled for lead, all of them children’s shoes, boots or sandals.
Limit one, total lead in the material
The 100 ppm limit comes from section 101(a) of the Consumer Product Safety Improvement Act of 2008 (CPSIA). The eCFR summary in 16 CFR 1500.87 lays out how it stepped down for “products designed or intended primarily for children 12 and younger”: 600 ppm by February 10, 2009, then 300 ppm after August 14, 2009, then 100 ppm on August 14, 2011. CPSC’s FAQ states the current rule plainly: accessible components of children’s products “must not contain more than 100 parts per million (ppm) of total lead content.”
This is the limit on the substrate, meaning the base material the part is made of: the rubber or plastic of a sole, the metal of a buckle, the foam of an insole. Two details in 16 CFR 1500.87 matter for shoes:
- Paint is not a shield. “Paint, coatings, or electroplating may not be considered to be a barrier that would render lead in the substrate to be inaccessible to a child.” A coated buckle is judged by the metal underneath as well as the coating.
- Hidden parts can be exempt, but only if they stay hidden. A part is inaccessible if a sealed covering keeps it from being exposed through “reasonably foreseeable use and abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product.” CPSC tests this with probes and with age-based use and abuse tests (separate sets for 18 months and under, 18 to 36 months, and older children).
Some materials are treated as already under the limit when untreated. The list in 16 CFR 1500.91(d) includes natural or cultured pearls, wood, textiles of natural or manufactured fiber whether dyed or undyed, and animal-derived materials such as fur, feathers and leather, “provided that these materials have neither been treated or adulterated” with anything that could add lead. Plastic pearls, painted logos and metal hardware are not on that list.
Makers and importers must have children’s products tested by a CPSC-accepted third-party lab and certify the results in a Children’s Product Certificate, according to the CPSC FAQ.
Limit two, lead in paint and coatings
The paint limit lives in 16 CFR part 1303. It bans paint and similar surface coatings with lead above 0.06 percent of the dried paint film, and adds that “0.06 percent is reduced to 0.009 percent effective August 14, 2009.” The same part bans “toys and other articles intended for use by children that bear ‘lead-containing paint’.” The 2009 Nordstrom and Timberland recall notices call it “the federal lead paint standard.”
The definition in 16 CFR 1303.2 is wide. Paint means a material that “changes to a solid film when a thin layer is applied to a metal, wood, stone, paper, leather, cloth, plastic, or other surface.” It does not include printing inks or materials that become part of the substrate, such as pigment mixed into a plastic. In one recall below, Timberland’s, the paint standard was applied to a logo stamped onto a boot’s insole.
The six lead recalls in our archive
| Year | Firm and product | Where the lead was | Units |
|---|---|---|---|
| 1999 | Nike Little Air Jordan XIV infant shoes | Red trim paint | About 110,000 pairs |
| 2009 | Alpargatas, Havaianas children’s flip flops | Decorative paint on the sole | About 210,000 |
| 2009 | Nordstrom girls’ shoes, six styles | Surface paint on the outer sole | About 31,000 |
| 2009 | Timberland children’s 6-inch boots | Logo stamped on the insoles | About 4,300 |
| 2020 | Kidz Concepts, Lilly of New York winter boots | The sole | About 3,200 |
| 2022 | Kolan, Otter MOMO children’s sandals | The inner layer | About 100 |
The table splits cleanly in two. The four older recalls were all about paint and coatings. Three of them fall in 2009, the year the paint limit dropped to 90 ppm on August 14: the Alpargatas and Nordstrom notices came out that March, Timberland’s in December. The two newest recalls are about the material itself, and their titles say “Violation of Federal Lead Content Ban,” the 100 ppm rule.
The two recent cases also share a sales channel. Lilly of New York boots were sold only on Zulily.com, from November 2019 through January 2020, for $35 to $40. Kolan’s sandals were sold only on Amazon.com from March through April 2022, for $22 to $26, in children’s sizes 6 to 12. Both were posted as Recall Alerts, where the firm contacts known buyers directly. Kolan’s notice tells owners to stop using the sandals and contact the firm to learn how to dispose of them and get a full refund. Our Otter MOMO sandals page has the batch number (#LIANG2201) and model numbers.
None of the six notices reports an injury. The only incident in the group is from 1999: Nike had received “one consumer complaint regarding the shoe and possible ingestion of a paint chip.” The same notice says the problem was found when “NIKE testing determined the red trim paint on these shoes contain amounts of lead that exceed Federal standards for children’s products.”
Remedies varied. Timberland offered free replacement insoles, since the problem was the insole logo (see our Timberland children’s boots page). Alpargatas offered a replacement pair. Nordstrom offered a refund or exchange, Lilly of New York a refund or a replacement of similar value. Our guide on refund, repair or replace remedies covers how those choices differ across all footwear recalls.
What you can and cannot tell by looking
You cannot see lead, and the rule makers know it. In an October 22, 2007 study, CPSC staff tested home lead test kits on consumer products. “Of 104 total test results, more than half (56) were false negatives, and two were false positives.” The kits did worse on coated items: “None of the kits consistently detected lead in products if the lead was covered with a non-leaded coating.” CPSC’s conclusion: “consumers should not use lead test kits to evaluate consumer products for potential lead hazards,” and testing by a qualified laboratory “is the only way to accurately assess” the risk.
The archive shows why a visual check would not help much. In two of the six cases the lead was in places a parent would not inspect: the inner layer of a sandal and a logo printed under the foot on an insole. In two others it was in decorative paint on the sole, which looks like any other print.
What you can check is the label. Every one of these notices lists identifiers printed on the shoe: model numbers on a white tag inside Timberland boots, style numbers on the inside of the tongue of the Lilly boots, a batch number on the heel strap of the Kolan sandals. Search our chemical hazard page or the full children’s footwear list by brand, and match those numbers.
If you are worried about a child’s exposure, CDC says “No safe blood lead level in children has been identified,” and that a blood test is how to find out whether a child has been exposed. Its advice to parents is to talk to the child’s health care provider about a blood lead test. Other chemicals that show up in shoe recalls, such as chromium VI in leather and benzidine dyes, are covered in our guide on chemicals in shoes.