Enacted in 2022, the STURDY law (15 U.S.C. § 2056f) directs CPSC to promulgate rulemaking for clothing storage units. Pursuant to STURDY, CPSC published a final rule in the Federal Register (88 FR 28403) that incorporates by reference ASTM F2057. The requirements are codified at 16 CFR part 1261 and apply to clothing storage units manufactured after September 1, 2023. 16 CFR § 1261.2 identifies the latest Commission-accepted version of ASTM F2057 that is mandatory.
A “clothing storage unit” is defined as a “furniture item with drawers and/or hinged doors intended for the storage of clothing typical with bedroom furniture” and meets all of the following criteria:
- Height of at least 27 inches
- Mass of at least 30 pounds
- Enclosed storage volume of at least 3.2 cubic feet
- Volume of an extendible element is the height (⅛ inch less than bottom of drawer to lowest obstruction point) multiplied by the width and depth (for uneven depth, use average of shortest and longest distances) of the extendible element
- Volume of non-extendible enclosed storage is 50% of the height multiplied by the width and depth of the storage area
Examples of clothing storage units include chests, chests of drawers, drawer chests, armoires, chifferobes, bureaus, door chests, and dressers. Products that are not within scope include bookcases or entertainment furniture, office furniture, dining room furniture, jewelry armoires, underbed drawer storage units, occasional/accent furniture not intended for bedroom use, laundry storage/sorting units, built-in units intended to be permanently attached to the building, and clothing storage chests as defined in ASTM F2598.
The requirements for clothing storage units are as follows:
- For products that come with interlocks, the interlocks shall not require additional consumer action to engage during normal operation. Also, the interlocks shall not require consumer assembly or installation if the unit is shipped assembled (consumer assembly and/or installation is allowed for items shipped/sold unassembled). To use the interlock during stability tests, an interlocked element must remain closed and retain function when subjected to 30 lb of force for 5 seconds or its opening must act to close the originally open element.
- Product must pass all three stability tests:
- Clothing load – Open all doors and extendible elements that are not locked with an interlock (affected by interlock evaluation); if more than 50% of the storage volume is extended, fill enclosed storage with 8.5 lb per ft3 of volume; and hold for 30 seconds
- Horizontal force – Apply 10 lb of force at highest hand-hold (no higher than 56 in.) for 10 seconds
- Carpet with child weight – Place the test block under the rear legs and hang the 60 lb test apparatus on the front of the door or extendible element most likely to cause tip-over for 30 seconds
- Anti-tip device that meets ASTM F3096 must be packaged with the product
- Warning labels must include certain statements and pictogram(s) dependent on intended use and design
Enforcement Policy for Warnings on Clothing Storage Units: With respect to non-substantive variances between the required textual warning statements and the example warning figures in the ASTM F2057-23 standard, the CPSC Office of Compliance and Field Operations will accept either warning for the purposes of compliance with 16 CFR part 1261.
Read-only copies of ASTM standards that are incorporated by reference can be viewed at ASTM’s electronic Reading Room. Note, only ASTM F2057 may be viewed for free. ASTM F2598 and ASTM F3096 must still be purchased from astm.org.
Section 14(a) of the Consumer Product Safety Act (CPSA) requires manufacturers and importers of consumer 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 certificate of compliance (Children’s Product Certificate or CPC for children’s products, General Certificate of Compliance or GCC for general-use products). For clothing storage units, the citation to use in section 2 of the CPC or GCC is “16 CFR part 1261 – Clothing storage units”.
- Frequently Asked Questions
- ASTM’s electronic Reading Room
- CPSC Business Education | CPSC Webinar: Requirements for Clothing Storage Units (CSUs) - YouTube & Webinar Slide Deck
For more information, please contact the Small Business Ombudsman (SBO) team: