Clothing Storage Units
The STURDY law (15 U.S.C. § 2056f) seeks to reduce the unreasonable risk of injury and death to children up to 72 months of age associated with clothing storage units tipping over.
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:
- Free-standing
- 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
Definitions, details on the requirements, and methodology can be found in ASTM F2057. 16 CFR § 1261.2 identifies the latest Commission-accepted version of ASTM F2057 that is mandatory. 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.
The rule was published in the Federal Register at 88 FR 28403 and codified at 16 CFR part 1261.
The test procedures can be found in ASTM F2057. 16 CFR § 1261.2 identifies the latest Commission-accepted version of ASTM F2057 that is mandatory. 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.
Yes. Manufacturers or importers of clothing storage units must issue 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 more information on certificates, please visit our CPC page or GCC page.
No, the requirements allow for testing of units that do not have an interlock. If the product does have an interlock, there are requirements for such devices. Units with interlocks that fail to meet the applicable requirements must undergo stability testing with the interlock disabled or bypassed.
Clothing storage units must bear a warning label that contains specific pictogram(s) and prescribed text as noted in ASTM F2057. Content of the warning label varies based on intended use and specific features of the unit. 16 CFR § 1261.2 identifies the latest Commission-accepted version of ASTM F2057 that is mandatory.
Read-only copies of ASTM standards that are incorporated by reference can be viewed at ASTM’s electronic Reading Room.
Yes. Such products are considered to be “consumer products” under the jurisdiction of CPSC and, therefore, are subject to applicable consumer product safety rules, such as 16 CFR part 1261, if they fall within the scope of the rule.
The scope applies to products manufactured after the effective date, regardless of whether they are manufactured domestically or overseas.
Neither the standard nor the regulation specifically prohibit this; however, CPSC staff highly recommends against shipping a stability feature separately for products that are shipped or sold to consumers pre-assembled due to the fact that this may encourage consumers NOT to install the feature.
An anti-tip kit that meets ASTM F3096 must be packaged with the clothing storage unit, but that does not exempt the manufacturer or importer from meeting applicable testing requirements under the standard. The clothing storage unit must meet the stability testing requirements of the standard without the anti-tip kit installed.