Comment from Eiichi Ogo

We are selling metal trims used for many famous apparel brands in U.S. As for the standard of lead in substrate- 100ppm, starting from 2011 Aug, we think that the standard is too strict to follow. Since recycled materials are used to produce brass which is common to be used for making metal buttons, it may contain lead over 100ppm. According to our brass material supplier's inhouse and 3rd party test report, it is far below 100ppm, but it may be difficult to comply with it 100% by any possibility. The master coil of brass is several tons, there will be no way to test 100%. Also even we do not use recycled materials, it may contained Lead as natural substance.