After reviewing the risk of strangulation to young children associated with certain window covering cords, the Consumer Product Safety Commission determined that window coverings that do not meet applicable sections of ANSI/WCMA A100.1—2018 are a substantial product hazard under section 15(j) the Consumer Product Safety Act (CPSA). The determination adds stock and custom window coverings to the “substantial product hazard” list at 16 CFR § 1120.3(e) and 1120.3(f), respectively. A product on the “substantial product hazard” list is subject to the mandatory reporting requirements of section 15(b) of the CPSA. 15 U.S.C. 2064(b).
Stock products that fail to meet the operating cord requirements, and stock and custom products that fail to meet the inner cord and manufacturer label requirements, will be deemed a substantial product hazard under the 15(j) rule.
A “stock window covering” is defined as a window covering that is completely or substantially fabricated before being distributed in commerce and before any specific consumer request for that product. Products that are modified or adjusted by the seller, manufacturer, or distributor would still be considered “stock” if they were substantially fabricated before or after distribution in commerce. See 16 CFR § 1120.2(f).
A “custom window covering” is defined as a window covering that does not meet the definition of a “stock window covering.”
Stock window coverings must meet one of the operating cord requirements in the following sections of ANSI/WCMA A100.1—2018:
- Section 4.3.1.1 - Cordless operating system: an operating system that does not have an operating cord (includes motorized operating systems)
- Section 4.3.1.2 - Short static or access cord; an operating cord or band that is fixed in length in any state (free or under tension), to be a length equal to or less than 8 inches
- Section 4.3.1.3 - Inaccessible operating cord: operating cords that are inaccessible as determined per the test requirements in Appendix C: Test Procedure for Accessible Cords
Per ANSI/WCMA A100.1—2018, all stock and custom window coverings must have inaccessible inner cords (when tested to Appendix C: Test procedure for accessible cords), or have accessible inner cords that are too short to form a hazardous loop (when tested to Appendix D: Hazardous Loop Test Procedure) and comply with Section 6.3 (Cord Shroud) and Section 6.7 (Inner cord stop device or cord connector), as applicable.
All stock and custom window coverings must meet the manufacturer label requirement in Section 5.3 of ANSI/WCMA A100.1—2018. All finished products shall have a permanent label or marking located within the headrail or on the roller tube identifying:
- The readily distinguishable name, city, and state of the manufacturer or importer of record or fabricator
- The month and year of manufacture
- The designation of the window coverings as “Custom” or “Stock,” using a “C” or the word “Custom” or an “S” or the word “Stock,” as applicable
- Customer order information (e.g., customer name or customer order number) to match the product with a specific order for custom window coverings
A read-only copy of the ANSI/WCMA A100.1—2018 standard is available here.
No, a 15(j) rule does not trigger a certification requirement under section 14(a) of the Consumer Product Safety Act (CPSA).
Section 15(j) of the CPSA gives the Commission the authority to specify, by rule, for a consumer product or class of consumer products, characteristics whose presence or absence the Commission considers a "substantial product hazard" under 15(a)(2) of the CPSA. This type of rule is referred to here as a "15(j) rule."
While a 15(j) rule does not establish a consumer product safety standard, placing a consumer product on this substantial product hazard list has certain consequences. A product that is, or has, a substantial product hazard must be reported under section 15(b) of the CPSA. 15 U.S.C. 2064(b). A manufacturer who fails to report a substantial product hazard to the Commission is subject to civil penalties under section 20 of the CPSA and possibly is subject to criminal penalties under section 21 of the CPSA. 15 U.S.C. 2069, 2070. A product that is, or contains, a substantial product hazard, is subject to corrective action under section 15(c) and (d) of the CPSA. 15 U.S.C. 2064(c), (d). Thus, the Commission can order the manufacturer, distributor, or retailer of the product to offer to repair or replace the product, or to refund the purchase price to the consumer. Finally, a product that is offered for import into the United States, and is, or contains, a substantial product hazard, must be refused admission into the United States under section 17(a) of the CPSA. 15 U.S.C. 2066(a).
If your window covering product fails to meet the requirements under the 15(j) rule, a section 15(b) report can be filed here.