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Soft Infant and Toddler Carriers Business Guidance & Small Entity Compliance Guide

Federal law requires that soft infant and toddler carriers comply with the soft infant and toddler carrier standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

 

Manufacturers and importers of soft infant and toddler carriers must certify in a Children's Product Certificate that the soft infant and toddler carriers comply with the standard and any additional requirements after the soft infant and toddler carriers have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are discussed below and atwww.cpsc.gov/BusinessEducation.

 

What is a soft infant and toddler carrier?

A soft infant and toddler carrier is a product normally of sewn fabric construction designed to carry a child (a full-term infant to a toddler), generally in an upright position, in close proximity to the caregiver.

 

What is the purpose of the soft infant and toddler carrier standard?

The standard seeks to minimize the risk of deaths and injuries associated with the use of soft infant and toddler carriers, including those related to caregiver falls, infant falls from carriers, or structural and design problems of carriers.

 

Where can I find the standard for soft infant and toddler carriers?

The standard is published in the Code of Federal Regulations at 16 CFR Part 1226. The standard incorporates by reference ASTM F2236-14, which details the specific requirements and descriptions of the tests for soft infant and toddler carriers.  ASTM F2236-14, the Standard Consumer Safety Specification for Soft Infant and Toddler Carriers, can be purchased from ASTM International.

 

What are the requirements for soft infant and toddler carriers?

The standard includes performance requirements specific to soft infant and toddler carriers, general performance requirements, and labeling requirements. The key provisions of the ASTM soft infant and toddler carrier standard include the following:

  • Fastener strength and strap retention – intended to ensure that fasteners do not break or disengage and straps do not slip through fasteners by any significant amount while the child is being transported in the carrier.
  • Dynamic and static load testing on seating area – intended to ensure that the child remains fully supported while being transported in the carrier.
  • Occupant retention – intended to prevent falls by setting requirements for bounded and unbounded leg openings.
  • Warnings – intended to alert the caregiver to infant fall and suffocation hazards and promote safe use of soft infant and toddler carriers.
  • Flammability – intended to ensure the product meets the flammability requirements of 16 C.F.R. part 1610

 

The standard also includes: (1) requirements prohibiting small parts; (2) requirements prohibiting hazardous sharp points and edges; (3) latching/locking mechanism requirements to ensure that the soft infant and toddler carrier remains in the manufacturer’s recommended use position during testing; (4) requirements for the permanency and adhesion of labels; (5) requirements for toy accessories to meet ASTM F963 Toy Safety standard; and (6) requirements for warnings and instructional literature.

 

What are the additional requirements for soft infant and toddler carriers required by the Consumer Product Safety Improvement Act of 2008?

Soft infant and toddler carriers are subject to requirements for surface coatings, lead, and (in certain circumstances) phthalate content, testing and certification, registration cards, and tracking labels. These requirements are discussed below and at www.cpsc.gov/BusinessEducation:

 

  • Surface Coating Limit: Soft infant and toddler carriers must not be painted with paint that contains more than 90 ppm (0.009 percent) lead.
  • Lead Content Limit: Soft infant and toddler carriers must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
  • Phthalate Content Limits: Soft infant and toddler carriers that contain plasticized parts that are designed, marketed, or intended to facilitate sleep or have plasticized components that are designed, marketed, or intended to facilitate eating, must not contain more than 0.1 percent of the following eight specified phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), diisobutyl phthalate (DIBP), di-n-pentyl phthalate (DPENP), di-n-hexyl phthalate (DHEXP), and dicyclohexyl phthalate (DCHP).
  • Testing and Certification: Soft infant and toddler carriers, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by a CPSC-accepted, third party laboratory for compliance with the soft infant and toddler carrier standard and all other applicable children’s product safety rules. Based on that testing, a domestic manufacturer (or importer) of soft infant and toddler carriers must issue a Children's Product Certificate specifying each applicable rule and indicating that the product complies with those rules.
  • Product and Outer Package Labeling Requirements:Durable infant or toddler products, such as soft infant and toddler carriers, must be permanently marked with specific labeling information, including tracking labels, on the product and on the packaging.  In addition, durable infant or toddler products are required to have additional product markings and a product registration card attached to the product.  This chart summarizes the specific labeling and registration requirements that durable infant and toddler products must meet.

 

Where can I find additional information?

For more information on the requirements for soft infant and toddler carriers, contact the U.S. Consumer Product Safety Commission:

  • Office of Compliance (for specific enforcement inquires): e-mail: section15@cpsc.gov; telephone: (800) 638-2772
  • Small Business Ombudsman (for general assistance understanding and complying with CPSC regulations): e-mail: Please use our Contact Form, which is the best way to get a fast response; telephone: (888) 531-9070.

 

To purchase copies of ASTM F2236-14, contact ASTM International at: www.astm.org or via telephone: (610) 832-9585.

 

This communication has been prepared for general informational purposes only.  This summary document does not, and is not intended to, constitute legal advice nor does it replace or supersede a manufacturer’s obligations to comply with all applicable laws, regulations, standards, or bans enforced by CPSC. This communication has not been reviewed or approved by the Commission, and does not necessarily represent their views. Any views expressed in this communication may be changed or superseded by the Commission.

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