Crib Mattresses Business Guidance and Small Entity Compliance Guide

What federal requirements exist for crib mattresses?

The U.S. Consumer Product Safety Commission (CPSC) published a final rule in the Federal Register (87 FR 8640), establishing a mandatory safety standard for crib mattresses. The standard, titled Safety Standard for Crib Mattresses incorporates by reference ASTM F2933-21, with additional performance requirements to address hazards associated with suffocation, entrapment, and lacerations. The standard includes additional warnings requirements to address the risk of SIDS and suffocation (ASTM F2933-21 can be viewed free of charge as a read-only document at: https://www.astm.org/products-services/reading-room.html). The rule is effective for products manufactured after August 15, 2022.

The final rule requires crib mattresses, including mattresses for full-size and non-full-size cribs, and after-market mattresses for play yards and non-full-size cribs, to comply with the Safety Standard for Crib Mattresses, 16 CFR part 1241, and with additional requirements, including those specified by the Consumer Product Safety Improvement Act of 2008 (CPSIA).

The Safety Standard for Crib Mattresses addresses many of the general hazards associated with the use of crib mattresses, such as sharp points and sharp edges; small parts; lead and other toxic substances in paints; finger entrapment; mattress dimension conformity; mattress thickness; and marking and labeling. The rule includes additional requirements to address suffocation due to overly soft mattresses, entrapment because of poor mattress fits, laceration(s) from exposed coil springs, and labeling to address suffocation and sudden infant death syndrome (SIDS).

What are crib mattresses?

ASTM F2933-21 defines a “crib” as a “bed that is designed to provide sleeping accommodations for an infant which have specific interior dimensions as determined by it being either a full size or non-full size crib.” Furthermore:

A “full size crib” is defined as a crib with dimensions of 52⅜ in. ± ⅝ in. (1330 mm ± 16 mm) by 28 in. ± ⅝ in. (711 mm ± 16 mm)
A “non-full size crib” is defined as a crib with interior length dimensions either greater than 55 in. (1397 mm) or smaller than 49¾ in. (1264 mm), or an interior width dimension either greater than 30⅝ in. (778 mm) or smaller than 25⅜ in. (645 mm), or both.

ASTM F2933-21 defines an “after-market mattress for play yard or non-full-size crib” as “a mattress sold or distributed for a play yard or non-full-sized crib.” Replacement mattresses, which are mattresses provided or sold by an original equipment manufacturer that are equivalent with respect to dimensions and specifications to the mattress that was provided with the original product, are not considered “after-market mattresses.” ASTM F2933-21 defines a “mattress” as “ticking filled with a resilient material used alone or in combination with other products intended or promoted for sleeping on it.”

What are the requirements of the Safety Standard for Crib Mattresses?

The following table summarizes which mechanical testing requirements apply to durable infant or toddler mattresses regulated by CPSC.

	Full Size Crib Mattress	OEM NFS Crib Mattress	Aftermarket NFS Crib Mattress	OEM Play Yard Mattress	Aftermarket Play Yard Mattress
ASTM F2933 - 21	X	X	X		X
Firmness Test	X	X	X		X
Compression Test	X
Cyclic-load Test for Coil Spring Cores*	X	X	X		X
16 CFR 1220/ASTM F406		X	X†
16 CFR 1221/ASTM F406				X	X†

*The cyclic-load test only applies to crib mattresses with coil springs.

†The crib mattress rule requires that after-market, non-full-size crib mattresses meet the applicable requirements in 16 CFR part 1220, and that after-market play yard mattresses meet the applicable requirements in 16 CFR part 1221.

Section 1241.2 of the final rule states that crib mattresses must comply with the applicable sections of ASTM F2933-21, except as provided in 16 CFR § 1241.2(b).

The ASTM F2933-21 general requirements for crib mattresses address numerous hazards, most of which are also found in other ASTM and CPSC juvenile product standards. ASTM F2933-21 contains requirements to address the following safety hazards common to many juvenile products:

Sharp points and edges,
Small parts,
Lead in paint and surface coatings,
Openings, and
Labeling.

Below is a list of the requirements specific to crib mattresses (see ASTM F2933-21 and 16 CFR part 1241 for specific test methodologies and requirements):

Mattress dimensions:
- Full-size crib mattresses must measure at least 27¼ in. (690 mm) wide and 51⅝ in. (1310 mm) long. In addition, a mattress with the test mattress sheet must not allow a corner gap exceeding 3.15 in. (80.0 mm).
  - The test sheet is a twice-washed, 100% cotton fitted sheet that is fitted for the mattress to be tested, with each sheet edge wrapped fully around the mattress to be tested. Work with the test laboratory to ensure the mattress is tested with an appropriately sized fitted sheet.
- Mattresses supplied with a non-full-size crib must meet the specifications for Stability, Cord Strap length, Mattresses for Rigid Sided Products, and Crib Side Height of 16 CFR part 1220. Thickness must provide minimum effective crib-side height dimension of at least 20 in. in the lowest position.
- After-market mattresses for non-full-size cribs are to be treated as “mattresses supplied with a non-full-size crib” when tested to the equivalent interior dimension of the product for which it is intended to be used.
After-Market Mattresses: Such mattresses must be at least the same size as the original mattress and lay flat in contact with any original mattress support structure. If the original mattress includes a floor support structure, the after-market mattress must also include a floor support structure that is at least as thick as the original. If the original mattress includes storage accommodations for the instruction manual, the after-market mattress must provide the same.
Seam Stitching: All accessible seams must be lock-stitched.
After-Market Mattresses for Play Yard: Mattresses for mesh/fabric-sided play yard products must meet the specifications for Stability, Cord/Strap Length, Mattress, Height of Sides, Floor Strength, and Mattress Vertical Displacement of 16 CFR part 1221. If the mattress is intended for a bassinet attachment of a play yard, the mattress must also meet the specifications for Pad Thickness for Fabric- or Mesh-Sided Products, Pad Dimensions, Side Height, and Bassinets with Segmented Mattresses of 16 CFR part 1218 when tested with each brand and model for which it is intended to replace the original mattress.
Mattress Firmness: All mattresses must not allow the feeler arm of the firmness test fixture to contact the sleep surface.
Coil Springs: If the mattress contains coils, the coil or any metal wire must not be exposed. The mattress must also pass a cyclic impact test.
Marking and Labeling: Crib mattresses must meet applicable marking and labeling requirements, such as manufacture information and warning labels. After-market mattresses must additionally specify the brand(s) and model number(s) of the product(s) in which the mattress is intended to be used.
Instructional Literature: Instructions are a separate document from any on-product marking and labeling, and must include information on assembly, maintenance, cleaning, and use, as applicable, and must be in English, at minimum. They must also include the same marking and warnings as those on the mattress.

What are the additional requirements for crib mattresses?

Crib mattresses are also subject to requirements for children’s products (i.e., products that are designed or primarily intended for children 12 years of age or younger), child care articles (products that are designed or intended to facilitate sleep or the feeding of children age 3 and younger, or to help such children with sucking or teething), and durable infant or toddler products (specific list of products here). The requirements for such products are discussed below and at CPSC’s Business Education page:

Lead in Paint and Surface Coating: Children’s products must not bear paint and surface coatings that contain more than 0.009 percent (90 ppm) lead.
Total Lead Content: Children’s products must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part. 16 CFR § 1500.87 addresses accessibility for the purposes of total lead content.
Phthalates: Child care articles must not contain greater than 0.1% (1000 ppm) of a regulated phthalate in any accessible component part. 16 CFR part 1199 addresses accessibility for the purposes of regulated phthalates.
Testing and Certification: Children’s products must be tested by a CPSC-accepted, third party laboratory for compliance to the applicable safety rules. Based on that testing, the domestic manufacturer (or U.S. importer) must generate a CPC certifying compliance to the applicable safety rules. Contact the CPSC-accepted test lab to determine if both the play yard/crib and related crib mattress are required in order for testing to the Standard to be completed.
Tracking Label: Children’s products must bear distinguishing, permanent marks on the product and the packaging that allow consumers to ascertain the manufacturer or private labeler, location, and date of manufacture, and detailed information on the manufacturing process (i.e.., batch or run number), and the specific source of the product (e.g., specific manufacturing plant).
Additional Labeling: Durable infant or toddler products must also bear permanent marks on the product that contain the manufacturer’s contact information (i.e., address and phone number), as well as the model’s name and number.
Product Registration Cards: Durable infant or toddler products are required to be accompanied by a postage-paid product registration card. Such cards must bear the name of the manufacturer or private labeler, manufacturer contact information (i.e., address and phone number), location and date of manufacture, and model name and number. Manufacturers must maintain a record of the names, addresses, e-mail addresses, and other contact information of consumers who register.
Mattresses: Mattresses are subject to both 16 CFR part 1632, Safety Standard for the Flammability of Mattresses and Mattress Pads, and 16 CFR part 1633, Safety Standard for the Flammability (Open Flame) of Mattress Sets.

Where can I find additional information on the requirements for crib mattresses?

For more information on the requirements for crib mattresses:

Visit our Regulatory Robot, designed to guide you through CPSC’s product safety requirements.
Ask our Small Business Ombudsman (for general assistance understanding and complying with CPSC regulations), using our Contact Form, which is the best way to get a fast response, or (888) 531-9070.