Business Guidance FAQ

The regulation seeks to minimize injuries to children from normal use and reasonably foreseeable misuse or abuse of baby changing products. Specifically, the regulation attempts to minimize injuries and fatalities to children due to: (1) falls from changing tables, (2) failure of structural or mechanical components, (3) instability and entrapment in openings in the table structure, and (4) suffocation.

The regulation was originally published at 83 FR 29672 and codified at 16 C.F.R. part 1235. The regulation incorporates by reference ASTM F2388, and 16 C.F.R. § 1235.2 identifies the latest Commission-accepted version of ASTM F2388 that is mandatory as well as any modifications by CPSC.

Read-only copies of ASTM standards that are incorporated by reference can be viewed at ASTM’s electronic Reading Room.

More information is available at our baby changing products business guidance page.

The term “baby changing product,” as defined in ASTM F2388, includes:

• Changing Table: an elevated, freestanding structure generally designed to support and retain a child with a body weight of up to 30 lbs. (13.6 kg) in a horizontal position for the purpose of allowing a caregiver to change the child’s diaper. Changing tables may convert from or to other items of furniture, such as, but not limited to, a dresser, desk, hutch, bookshelf, or play yard, may have pull-out or drop-down changing surfaces, and they may provide storage for diapers and diaper products.
• Changing Table Accessory: an accessory that attaches to a crib or play yard designed to convert the product into a changing table, typically having a rigid frame with soft fabric or mesh sides or bottom surface, or both.
• Add-On Changing Unit: a rigid addition to or separate product used with an item of furniture that provides barriers to prevent the infant from rolling off the product during a diaper change.
• Contoured Changing Pad: a changing pad designed for use on an elevated surface that incorporates barriers to prevent a child from rolling off the changing surface and that often consists of synthetic-covered foam with contoured edges.

Only products defined as “baby changing products” are subject to this standard—flat, non-contoured changing mats that are typically included with a diaper bag, for example, are not covered under this definition, and therefore, are not subject to this standard.

The requirements for baby changing products per ASTM F2388 are as follows:

• General requirements
  • 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
  • Surface coatings – see also our lead in paint business guidance page
  • Wood parts
  • Openings
  • Additional requirements for changing table accessories
  • Toys – any toy accessories must meet the applicable requirements for children’s toys
  • Threaded features
  • Protective components
  • Scissoring, shearing, and pinching
• Performance requirements
  • Structural integrity
  • Stability
  • Barriers
  • Retention of contoured changing pads and add-on changing units
  • Entrapment in enclosed openings
  • Entrapment by shelves
  • Self-folding steps
  • Restraint system

For details on the individual requirements, firms should review the latest Commission-accepted version of ASTM F2388 as referenced at 16 C.F.R. § 1235.2. Read-only copies of ASTM standards that are incorporated by reference can be viewed at ASTM’s electronic Reading Room.

Yes. There are general requirements for children’s products and durable infant or toddler products that apply:

• Small parts: Products intended for children under 3 years of age must not contain small parts or liberate small parts after use and abuse testing.
• Lead in paint and similar surface coatings: Children’s products must not bear paint and/or similar surface coatings that contain more than 0.009 percent (90 ppm) lead.
• Total lead content: Children’s products must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
• Third-party testing: Children’s products must be tested for compliance to applicable safety rules by a third-party, CPSC-accepted laboratory.
• Certification: Domestic manufacturers or importers of children’s products must generate a Children’s Product Certificate (CPC) certifying compliance to the applicable safety rules and ensures that a CPC accompanies the distribution of the product.
• Labeling: Children’s products must bear distinguishing, permanent marks on the product and any packaging (tracking label) that allow consumers to ascertain certain information. Durable infant or toddler products are required to have product markings in addition to the tracking label. This chart summarizes the specific labeling and registration requirements that durable infant and toddler products must meet.
• Registration form: Durable infant or toddler products must have a product registration form (also known as registration card) permanently attached to the product. There must also be an option to register via a website or, in the absence of a website, via email.

For detailed information on the requirements in place for your consumer product, please visit CPSC’s Regulatory Robot tool: https://business.cpsc.gov/robot.

For detailed information on the requirements in place for your consumer product, please visit CPSC’s Regulatory Robot tool: https://business.cpsc.gov/robot.

In order to improve recall effectiveness, Congress has required that manufacturers of covered products:

1. Provide consumers with a postage-paid registration form (also known as registration card) with each product;
2. Maintain a record of the names, addresses, e-mail addresses, and other contact information of consumers who register their products; and
3. Permanently place the manufacturer name and contact information, model name and number, and the date of manufacture on each durable infant or toddler product.

For more information, visit our registration form business guidance page.

Product registration cards are required for all durable infant and toddler products in order to enable the manufacturer or retailer of the product to contact consumers with recall or other safety information. The exact requirements for the postage-paid cards – the details of the text and the required format – are described in detail in the final rule, as corrected. More information on product registration cards is provided in the FAQs below.

The product registration card must be attached to the surface of the durable infant or toddler product so that the consumer will notice and handle the form after purchasing the product.

The product registration card has certain information already on it, such as the manufacturer's name and contact information, the model name and number (or other identifier), and the date of manufacture. The consumer provides his/her name, address, telephone number, and e-mail address.

The product registration card must provide an option for the consumer to register the product through the internet or via e-mail.

Firms must maintain a record of the names, addresses, e-mail addresses, and other contact information of consumers who register their ownership of a durable infant or toddler product. Firms must only use this information to notify the consumer of safety alerts or recalls regarding the product and are prohibited from using this information for marketing, promotional, or any other purpose.

The domestic manufacturer or importer must permanently place the firm’s name and contact information (U.S. address and phone number, toll-free if available), model name and number, and the date of manufacture on each durable infant or toddler product.

The rule applies to the following product categories: 

• Baby Changing Products
• Bassinets and Cradles
• Bedside Sleepers
• Booster Seats
• Carriages and Strollers
• Children’s Folding Chairs and Stools
• Crib Mattresses
• Cribs (Full-Size)
• Cribs (Non Full-Size)
• Frame Child Carriers
• Gates and Enclosures
• Hand-Held Infant Carriers
• High Chairs
• Infant Bath Seats
• Infant Bath Tubs
• Infant Bouncer Seats
• Infant Sleep Products
• Infant Swings
• Infant Walkers
• Play Yards
• Portable Bed Rails
• Portable Hook-On Chairs
• Sling Carriers
• Soft Infant and Toddler Carriers
• Stationary Activity Centers
• Toddler Beds

No.  A single product registration card attached to one of the principal components is sufficient. 

No. Accessories sold separately are not covered by the registration rule.

The domestic manufacturer or the importer (of foreign made products) is responsible for compliance.

Marking or labeling must be permanently affixed to the product.

Yes. Section 104(d) of the Consumer Product Safety Improvement Act states that the product registration rule, which contains these requirements for marking or labeling, is a consumer product safety rule. A consumer product that fails to comply with an applicable consumer product safety rule shall be refused admission per 15 U.S.C. § 2066(a)(1). Alternatively, the CPSC may request that Customs and Border Protection (CBP) seize and forfeit the product under the Tariff Act.

If a product is not marked or labeled at the time of importation, it still may be physically entered into the United States, but it will not be deemed legally admissible into the United States until marking or labeling occurs.

The product can be entered into the United States for warehousing, and it can be marked or labeled in the warehouse before it is withdrawn for consumption. You can file a consumption entry with Customs and Border Protection (CBP), and the product may be released conditionally by the CPSC and CBP under the CBP basic importation bond for the purposes of marking or labeling the product at the importer's premises or another location agreeable to the CPSC and CBP.

If an importer seeks to use these options to mark or label its product, the product is subject to an inspection by CPSC staff to verify that the newly affixed markings and labels satisfy the requirements.

The CPSC will notify the importer of the duration of the conditional release period on a case-by-case basis, although the typical timeframe will be 30 days. Individual circumstances concerning the type of product and the complexity of marking and labeling will be taken into account.

If a product is refused admission, it must be destroyed at the importer's expense or exported under government supervision. Failure to export or destroy the product will result in the assessment of liquidated damages against the importer, usually in an amount equal to three times the value of the product upon entry into the United States. Alternatively, the CPSC may request that Customs and Border Protection (CBP) seize and forfeit the product under the Tariff Act.

If the importer did not make registration cards available, or failed to attach the registration cards to the products that are subject to the requirements, the importer may be held liable.

No. The importer may use a website established by others, or the importer may provide an e-mail address where consumers can send their registration information, but only if the importer lacks a website for consumers to register their products. If importers provide an e-mail address, the e-mail address must be set up to provide an automatic reply to confirm receipt of the consumer's information. Limited information is required for the consumer to submit the registration form.

Yes. If necessary, the importer is allowed to use the facilities and capabilities of a third party located in the United States for maintaining these records.

No. The primary requirement is to have a postage-paid registration form physically attached to the product. A website or email registration is a secondary requirement that does not replace the physical form requirement. Both requirements must be fulfilled to comply.