That would be 650000ppm. A whopping amount to be sure
The question is whether a metallic reduction surface constitutes a coating or not. The 90ppm comes from the paint and coating rule. I think that the key word in the rule is 'similar' and how the word is defined. To my knowledge there has not been a test case on this point yet.
'Section 101. Children's Products Containing Lead; Lead Paint Rule
In addition, after 1 year or August 14, 2009, the Act provides that paint and similar surface-coating materials for consumer use must be reduced from 600 ppm to 90 ppm.' (
http://www.cpsc.gov/about/cpsia/sect101.html)
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