U.S. - CPSC Final Rule: Safety Standard for Soft Infant and Toddler Carriers

Vol. 1436 | 25 Nov 2024

On November 20, 2024, the U.S. Consumer Product Safety Commission (CPSC) staff published a Direct Final Rule in the Federal Register, updating the safety standard for soft infant and toddler carriers.

This final rule references the latest version of the ASTM F2236 standard, which includes several key revisions.

ASTM F2236 applies to soft infant and toddler carriers, defined as “a product, normally of sewn fabric construction, which is designed to contain a full-term infant to a toddler, generally in an upright position, in close proximity to the caregiver.” The soft infant and toddler carrier is normally “worn” by the caregiver with a child positioned in the carrier and the weight of the child and carrier suspended from one or both shoulders of the caregiver. These products may be worn on the front, side, or back of the caregiver's body with the infant either facing towards or away from the caregiver. This consumer safety specification does not include products generally referred to as “slings.”

What's Changing?

The updated standard, ASTM F2236-24, replaces the previous version, ASTM F2236-14. The changes include:

• Terminology revision: The definition of static load is revised as “Vertically downward load applied by weights or other means." This is a modification in wording and there is no change to the substantive meaning of the terms.
• Flammability Revisions:
  • The section is renamed to "Flammability of Soft Infant and Toddler Carriers" for clarity. The term "product" is replaced with "fabrics" in section 5.7.1 to specify that fabrics, rather than products, are subject to flammability requirements.
  • Section 5.7.2 is revised to clarify that components of the product containing padding materials must meet specific flammability requirements. The revised standard specifies that fabrics are subject to 16 CFR 1610, while padding components are tested to 16 CFR 1500.3(c)(6)(vi) for flammable solids, using the test method in Consumer Safety Specification F963.
  • The revised standard includes a note referencing exemptions for flammability testing listed in 16 CFR 1610.1(d) and 1610.6(a)(1)(vi). A new requirement is introduced, mandating that non-toy accessories sold with and intended to be attached to the product must also meet the flammability requirements of section 5.7.
• Marking and labeling:
  • An additional warning statement is introduced for carriers that allow nursing, instructing caregivers to reposition their baby after nursing to prevent suffocation hazards.
  • Revisions aim to improve the clarity, readability, and consistency of warning labels and markings. Key changes include:
    • Requirements for warnings to be easy to read and understand, in English, and conforming to ANSI Z535.4-2011.
    • Prohibition of additional markings or labels that contradict required information.
    • Specifying font sizes, layouts, and formatting for warning labels.
    • Requirements for permanent markings and labels on the product.
  • Contact information for manufacturers, distributors, or sellers must be included on the product and packaging.
  • Some instances of the words "infant," "infants," "child," and "children" have been replaced with "baby" or "babies" in warning statements.
• Instructional Literature Revisions: The standard now requires instructions to be in English, warnings to meet specific contrast requirements, and additional instructions to not contradict or confuse required information. These revisions improve safety by providing clear and consistent messaging.
• Non-Substantive Revisions: The standard includes minor editorial revisions, such as formatting changes, adjustments to section and figure numbers, and updates to the Rationale section. These revisions do not alter substantive requirements and are neutral regarding safety.

The Consumer Product Safety Act (CPSA) requires manufacturers, including importers, to certify that their products comply with all applicable CPSC requirements.

What Does This Mean for Manufacturers?

The updated safety standard will become effective on February 22, 2025, unless significant adverse comments are received by the CPSC by December 20, 2024. If the CPSC receives such a comment, it will publish a document in the Federal Register, withdrawing this direct final rule before its effective date.

Manufacturers of soft infant and toddler carriers must ensure their products comply with the new standard to avoid any regulatory issues.

Conclusion

The update to the safety standard for soft infant and toddler carriers reflects the CPSC's ongoing commitment to ensuring the safety of consumer products. By referencing the latest version of the ASTM F2236 standard, manufacturers can help prevent injuries and provide safer products for consumers.

For questions, please contact Andrew Loveland (andrew.loveland@intertek.com) and Harini Ramaswamy (harini.ramaswamy@intertek.com).