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 (89 FR 85388) a final rule which codifies the regulation for nursing pillows at 16 C.F.R. part 1242. The requirements apply to products manufactured after April 23, 2025.
A nursing pillow is defined as a product intended, marketed, or designed to position and support an infant close to a caregiver’s body while breastfeeding or bottle feeding, including any removable covers, or slipcovers, sold on or together with such a product. These products rest upon, wrap around, or are worn by a caregiver in a seated or reclined position.
The regulation excludes maternity pillows (aka pregnancy pillows) defined as a large body pillow intended, marketed, and designed to provide support to a pregnant adult’s body during sleep or while lying down; sling carriers as defined at 16 C.F.R part 1228; and soft infant and toddler carriers as defined at 16 C.F.R part 1226.
Please note, the nursing pillows rule does not affect or amend the existing infant pillow ban. As such, 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):
- Has a flexible fabric covering, see definition of “fabric” in section 2(f) of the FFA at 15 U.S.C. § 1191(f)
- Loosely filled with a granular material (e.g., polystyrene beads or pellets)
- Easily flattened
- Capable of conforming to the body or face of an infant
- Intended or promoted for use by children under one year of age
In addition, a nursing pillow that also meets the definition of an infant support cushion – defined as an infant product filled with or comprised of resilient material 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 removable covers or slipcovers sold on or together with an infant support cushion) – must comply with 16 CFR part 1243; more information is available on our infant support cushions business guidance page.
The requirements for nursing pillows are as follows:
- General requirements
- Lead in paint – see also our lead in paint business guidance page
- Small parts – see also our small parts business guidance page
- Hazardous sharp edges or points – see also 16 C.F.R. §§ 1500.3(b)(4)(i)(D) and 1500.3(b)(15)(i)(A)
- Removable of components
- Permanency of labels and warnings
- Performance requirements
- Firmness
- The force to displace the pillow 1 inch using the 3-inch diameter head probe must exceed 10.0 N
- Infant containment
- A 9-inch head probe must extend beyond the opening of the product, and the outer half of the probe cannot contact inner wall of the opening (see visual examples below)
- A 9-inch head probe must extend beyond the opening of the product, and the outer half of the probe cannot contact inner wall of the opening (see visual examples below)
- Infant restraints
- Nursing pillows 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
- Caregiver attachment strength
- The portions of the nursing pillow intended to secure the product to the caregiver during use (e.g., buckled belt, strap, etc.) must bear 20 lb. of force applied evenly over 5 seconds and maintained for an additional 10 seconds
- Firmness
Labeling
Nursing pillows must permanently bear the following warning label:
Similar verbiage other than what is shown can be used as long as the meaning is the same or information that is product-specific is presented. Warning labels that are sewn-in must have the entire perimeter in contact with the fabric (i.e., sewn-in on all four sides).
Packaging that accompanies nursing pillows must include warning statements about not using the product for sleep or in sleep products such as cribs, bassinets, or play yards; information about the manufacturer's recommended weight, height, age, or developmental stage; and a prohibition against other warnings, statements, or graphics that indicate or imply that an infant can be left in the product without an adult caregiver present.
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.
Instructional Literature Requirements
Instructional literature requirements include all on-product warnings and to instruct consumers to read all instructions before using the product, to keep the instructions for future use, and not to use the product if it is damaged or broken. Like the package requirements, the instructions must provide information about the manufacturer's recommended weight, height, age, or developmental stage, at a minimum. Section 9 of ASTM F3669—24 also includes these instructional literature requirements.
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 nursing pillows, the citation to use in section 2 of the CPC is “16 CFR part 1242 – Nursing pillows”.
For more information on certification, visit our CPC business guidance page.
Additional Information
- Nursing Pillows 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