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Infant Support Cushions Business Guidance

Section 104(b)(1) of the Consumer Product Safety Improvement Act of 2008 requires the CPSC to promulgate rules for durable infant or toddler products. Implementing that Congressional instruction, CPSC published in the Federal Register (89 FR 87467) a final rule that codifies the regulation for infant support cushions at 16 C.F.R. part 1243. The requirements apply to products manufactured after May 5, 2025.

An infant support cushion is defined as an infant product that is filled with or comprised of resilient material such as foam, fibrous batting, or granular material or with a gel, liquid, or gas, and which is marketed, designed, or intended to support an infant’s weight or any portion of an infant while reclining or in a supine, prone, or recumbent position, including any removable covers, or slipcovers, sold on or together with such a product.

Examples of infant support cushions include infant positioners (products intended to help keep an infant in a particular position while supine or prone), nursing pillows with a dual use for lounging, infant loungers (infant support cushion with a raised perimeter, a recess, or other area that provides a place for an infant to recline or to be in a supine, prone, or recumbent position), and infant props or cushions used to support an infant.

The regulation excludes products that are subject to another durable infant or toddler product standard as listed at 16 CFR § 1130.2(a), except for nursing pillows that also meet the definition of an infant lounger.

Please note, the infant support cushions rule does not affect or amend the existing infant pillow ban. As such, certain infant pillows and infant cushions that meet all of the following criteria are still considered banned hazardous substances per 16 CFR § 1500.18(a)(16):

  1. Has a flexible fabric covering, see definition of “fabric” in section 2(f) of the FFA at 15 U.S.C. § 1191(f)
  2. Loosely filled with a granular material (e.g., polystyrene beads or pellets)
  3. Easily flattened
  4. Capable of conforming to the body or face of an infant
  5. Intended or promoted for use by children under one year of age

The requirements for infant support cushions are as follows:

  • General requirements
  • Performance requirements
    • Restraint
      • Infant support cushions are prohibited from having restraints
    • Seam strength
      • Seams must withstand 15 lb. of force applied evenly over 5 seconds and maintained for an additional 10 seconds
    • Bounded openings
      • Bounded openings that allow the passage of the small head probe must also allow passage of the large head probe
    • Maximum incline angle
      • Incline angle must not exceed 10°
        Diagram Description automatically generated
    • Firmness
      • Force to displace 1 inch of the occupant support surface, sidewall, and intersection of the sidewall and occupant support surface using the 3-inch diameter head probe must exceed 10.0 N
    • Sidewall angle
      • Infant support cushions with a sidewall must have a sidewall angle greater than 90° 

Labeling

Infant support cushions must permanently bear either of the following warning labels, depending on whether or not the product has a tummy time feature: 

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.

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 infant support cushions, the citation to use in section 2 of the CPC is “16 CFR part 1243 – Infant support cushions”.

For more information on certification, visit our CPC business guidance page.

Additional Information

Contact

For more information, please contact the Small Business Ombudsman (SBO) team:

Report an unsafe product