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POMEGRANATE COMMUNICATIONS, INC.

CPSIA CERTIFICATION FORM CERTIFICATION REGARDING CHILDREN’S PRODUCTS


Pomegranate Communications, Inc. certifies the following as of March 1, 2009:

Products Marketed to Adults that may be used by children:
While some of Pomegranate’s products may be used by people of all ages, the federal Consumer Product Safety Commission (CPSC) specifically excludes such products from being governed by the Consumer Product Safety Improvement Act of 2008. Please see the Commission’s Guide at http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf

As for any products that Pomegranate has designed, manufactured, and/or supplies to our customers specifically for children twelve years of age and under, Pomegranate certifies as follows:


LEAD PAINT CERTIFICATION

Following the date of this certification, all Children’s Products manufactured by Pomegranate for supply to our customers will be below the August 14, 2009 Consumer Product Safety Improvement Act of 2008 (CPSIA) lead paint limit of 90 ppm and will be tested by accredited third party laboratories as defined in the CPSIA or will fall under an exclusion being considered by the CPSC for children’s books and/or publications made with ordinary paper and ink. Such exclusion is being considered by the CPSC in the face of overwhelming evidence of the negligible amount of lead found in ordinary paper, ink, and coatings. See testing data for paper, ink, and coatings at http://www.rrd.com/wwwCPSIA/home.asp#. Also see the data compiled by our print broker at http://www.pchaninc.com/cpsia.html.


LEAD CONTENT CERTIFICATION

Following the date of this certification, all Children’s Products manufactured by Pomegranate for supply to our customers will be below the August 14, 2009 CPSIA lead content limit of 300 ppm and will be tested by accredited third party laboratories as defined in the CPSIA or will fall under an exclusion being considered by the CPSC for children’s books and/or publications made with ordinary paper and ink. Such exclusion is being considered by the CPSC in the face of overwhelming evidence of the negligible amount of lead found in ordinary paper, ink, and coatings. See testing data for paper, ink, and coatings at http://www.rrd.com/wwwCPSIA/home.asp#. Also see the data compiled by our print broker at http://www.pchaninc.com/cpsia.html.


PHTHALATE CERTIFICATION

What is a “phthalate”?
(From the CPSC guide at http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf ) Phthalates are a group of chemicals (oily, colorless liquids) that are used, among other things, to make vinyl and other plastics soft and flexible. Many types of phthalates are in use today. As of February 10, 2009, three have been prohibited outright in the United States for use in certain products and three more are prohibited pending further action by the Commission.

Following the date of this certification, all Children’s Products manufactured by Pomegranate for supply to our customers that are manufactured on or after February 10, 2009 will comply with the CPSIA phthalate concentration level requirements.
(Please Note: The General Counsel of the U.S. CPSC has, by letter dated December 23, 2008 indicated that: “ordinary books intended or designed primarily for children 12 or younger are reading materials and not toys and, therefore, the phthalates provisions of the CPSIA do not apply to them. The phthalates provisions of the CPSIA would apply only to those books that have some inherent play value and constitute toys or have toy like features.” The full text of the General Counsel’s letter can be found at the following url: http://www.cpsc.gov/library/foia/advisory/323.pdf.)
In the General Counsel’s letter referred to herein, they apply the same analysis to “educational magazines, posters, bookmarks and other such products [such as flash cards] that are printed on cardboard or paper and have no play value.”

Results from Phthalate testing among the various book components - Paper, Ink, Coatings, Adhesives, and Wire used for binding are “not detectable” and statements from suppliers confirm that phthalates are not used in the manufacturing process of the book components. For test results see http://www.rrd.com/wwwCPSIA/home.asp. Also see the data compiled by our print broker at http://www.pchaninc.com/cpsia.html


MANUFACTURING TRACKING INFORMATION

Pomegranate’s children’s products all contain tracking information sufficient to identify the manufacturing date and location of the product, and any other manufacturing tracking requirements pursuant to the provisions of the CPSIA of August 2008, and any modifications thereto.
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