Section 104(b)(1) of the Consumer Product Safety Improvement Act of 2008 requires the CPSC to promulgate rulemaking for durable infant or toddler products. Implementing that Congressional instruction, CPSC published in the Federal Register (83 FR 28358) a final rule codifies the regulation for high chairs at 16 C.F.R. part 1231 and incorporates by reference ASTM F404, with any modifications by CPSC. 16 C.F.R. § 1231.2 identifies the latest Commission-accepted version of ASTM F404 that is mandatory as well as any modifications. See the “Previous Versions of the Standard” section below for effective dates.
A high chair is a freestanding chair for a child up to 3 years of age that has a seating surface more than 15 inches above the floor and elevates the child normally for the purposes or feeding or eating.
The requirements for high chairs are as follows:
- General requirements
- Compliance when used with conversion kits
- Threaded features
- 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
- Wood parts
- Latching or locking mechanisms
- Labeling
- Openings
- Toys - any toy accessories must meet the applicable requirements for children's toys
- Paint and surface coating– see also our lead in paint business guidance page
- Performance requirements
- Protective components
- Removable tray or front torso support performance integrity
- Tray or front torso support performance - pull test
- Static load
- Stability
- Exposed coil springs
- Scissoring, shearing, and pinching
- Restraint system
- Openings
- Structural Integrity
- Tray latch release mechanisms
- Side containment
- Protrusions
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 Version 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 F404 depending on its date of manufacture:
| Manufactured after... | Must meet... |
|---|---|
| July 23, 2022 | ASTM F404-21 |
| July 3, 2021 | ASTM F404-20 |
| June 19, 2019 | ASTM F404-18 |
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 high chairs, the citation to use in section 2 of the CPC is “16 CFR part 1231 — High chairs”.
For more information on certification, visit our CPC business guidance page.
Additional Information
- High chairs FAQs
- Durable infant or toddler product business guidance page
- Registration forms business guidance page
Contact
For more information, please contact the Small Business Ombudsman (SBO) team:
- SBO contact form
- Toll-free: (888) 531-9070
- Email: SBO@cpsc.gov