Section 104(b)(1) of the Consumer Product Safety Improvement Act of 2008 requires the CPSC to promulgate safety rules for durable infant or toddler products. Implementing that Congressional instruction, CPSC published in the Federal Register (83 FR 29682) a final rule that codifies the regulation for baby changing products at 16 C.F.R. part 1235 and incorporates by reference ASTM F2388, with any modifications by CPSC. 16 C.F.R. § 1235.2 identifies the latest Commission-accepted version of ASTM F2388 that is mandatory as well as any modifications. See the “Previous Versions of the Standard” section below for effective dates.
ASTM F2388 defines the following types of baby changing products:
- An “add-on changing unit” is “a rigid addition to or separate product used in conjunction with an item of furniture that provides barriers to prevent the infant from rolling off the product when a diaper is being changed”
- A “changing table” is “an elevated, freestanding structure generally designed to support and retain a child with a body weight of up to 30 lb. (13.6 kg) in a horizontal position for the purpose of allowing a caregiver to change the child’s diaper”
- A “changing table accessory” is “an accessory that attaches to a crib or play yard designed to convert the product into a changing table typically having a rigid frame with soft fabric or mesh sides or bottom surface, or both”
- A “contoured changing pad” is “a changing pad designed for use on an elevated surface which incorporates barriers to prevent a child from rolling off the changing surface”
The requirements for baby changing products are as follows:
- General requirements
- Sharp points and edges – see also 16 C.F.R. §§ 1500.3(b)(4)(i)(D) and 1500.3(b)(15)(i)(A)
- Small parts – see also our small parts business guidance page
- Surface coatings – see also our lead in paint business guidance page
- Wood parts
- Openings
- Additional requirements for changing table accessories
- Toys – any toy accessories must meet the applicable requirements for children’s toys
- Threaded features
- Protective components
- Scissoring, shearing, and pinching
- Performance requirements
- Structural integrity
- Stability
- Barriers
- Retention of contoured changing pads and add-on changing units
- Entrapment in enclosed openings
- Entrapment by shelves
- Self-folding steps
- Restraint system
Read-only copies of ASTM standards that are incorporated by reference can be viewed at ASTM’s electronic Reading Room.
Labeling
Per 16 C.F.R. § 1130.4, the following information must be permanently affixed to durable infant or toddler products in English:
- Name of manufacturer or importer
- Contact information (must include US address and phone number, toll-free if available)
- Model name/number
- Product identification number may be used as an identifying feature instead
- Date of manufacture
- Date must be at least month and year, and it can be stated in code form
This labeling requirement is in addition to the tracking label requirement for children’s products. This page summarizes the labeling requirements for durable infant or toddler products.
Registration Form
Product registration forms are required for all durable infant and toddler products to enable the manufacturer or retailer of the product to contact consumers with recall or other safety information. For more information, visit our registration forms business guidance page.
Previous Versions of the Standard
15 U.S.C. § 2056a(b)(4)(B) requires the CPSC to evaluate any updates to an incorporated ASTM standard for durable infant or toddler products to determine whether the revised standard improves the safety of the product. Firms must ensure that the product is tested to the Commission-accepted version of ASTM F2088 depending on its date of manufacture:
| Manufactured after... | Must meet... |
|---|---|
| July 31, 2022 | ASTM F2388-21 |
| June 26, 2019 | ASTM F2388-18 |
Certification
Section 14(a) of the Consumer Product Safety Act (CPSA) requires manufacturers and importers of children’s products subject to a regulation, standard, or ban enforced by the CPSC to certify that those products meet the requirements of the standard by issuing a Children’s Product Certificate (CPC). For baby changing products, the citation to use in section 2 of the CPC is “16 CFR part 1235 – Baby changing products”.
For more information on certification, visit our CPC business guidance page.
Additional Information
- Baby changing products FAQs
- Durable infant or toddler product business guidance page
- Registration forms business guidance page
Contact
- SBO contact form
- Toll-free: (888) 531-9070
- Email: SBO@cpsc.gov