Section 104(b)(1) of the Consumer Product Safety Improvement Act of 2008 requires the CPSC to promulgate safety rules for durable infant or toddler products. Implementing that Congressional instruction, CPSC published in the Federal Register (82 FR 15615) a final rule that codifies the regulation for infant bath tubs at 16 C.F.R. part 1234 and incorporates by reference ASTM F2670, with any modifications by CPSC. 16 C.F.R. § 1234.2 identifies the latest Commission-accepted version of ASTM F2670 that is mandatory as well as any modifications. See the “Previous Versions of the Standard” section below for effective dates.
An “infant bath tub” is a “tub, enclosure, or other similar product intended to hold water and be placed into an adult bath tub, sink, or on top of other surfaces to provide support or containment, or both, for an infant in a reclining, sitting, or standing position during bathing by a caregiver”.
Infant bath tubs within the scope of the regulation include products of various designs such as bucket-style tubs that support a child sitting upright, tubs with an inclined seat for infants too young to sit unsupported, inflatable tubs, folding tubs, and tubs with spa features, such as handheld shower attachments and even whirlpool settings. ASTM F2670 permits infant bath tubs to have “a permanent or removable passive crotch restraint as part of their design” but does not permit “any additional restraint system(s) which requires action on the part of the caregiver to secure or release the restraint”.
The requirements for infant bath tubs are as follows:
- General requirements
- Hazardous 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
- Lead in paints – see also our lead in paint business guidance page
- Latching or locking mechanisms
- Scissoring, shearing, and pinching
- Openings
- Protective components
- Toys – any toy accessories must meet the applicable requirements for children’s toys
- Labeling
- Compliant of multi-use products
- Performance requirements
- Restraint system
- Static load
- Specific requirements for suction cups
- Structural integrity/attachments of infant bath tub accessories
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 Versions 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 F2670 depending on its date of manufacture:
| Manufactured after... | Must meet... |
|---|---|
| September 24, 2022 | ASTM F2670-22 |
| January 15, 2019 | ASTM F2670-18 |
| October 2, 2017 | ASTM F2670-17 |
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 bath tubs, the citation to use in section 2 of the CPC is “16 CFR part 1234 – Infant bath tubs”.
For more information on certification, visit our CPC business guidance page.
Additional Information
- Infant bath tubs FAQs
- Durable infant or toddler product business guidance page
- Registration forms business guidance page
Contact
- SBO contact form
- Toll-free: (888) 531-9070
- Email: SBO@cpsc.gov