Federal law requires that children’s folding chairs and stools comply with the Safety Standard for Children’s Folding Chairs and Stools, 16 CFR Part 1232 (Effective July 6, 2020), and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA). This mandatory standard does not include non-folding chairs and stools.
Manufacturers and importers of children’s folding chairs and stools must certify in a Children's Product Certificate (CPC) that their products comply with the mandatory standard and any additional CPSIA requirements after the products have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are discussed below and at: www.cpsc.gov/BusinessEducation.
Children’s folding chairs and stools are defined as “a children’s chair or stool which can be folded for transport or storage.” Children’s chairs are “seating furniture with a rigid frame that is intended to be used as a support for the body, limbs, or feet of a child when sitting or resting in an upright or reclining position.” A children’s stool is a “children’s chair without back or armrests.”
Children’s folding chairs and stools within the scope of the standard have a seat height of 15 inches or less, may or may not have a rocking base, and allow a child to get in and out of the product unassisted. This standard does not apply to seats with restraint systems or children’s potty chairs.
The standard seeks to address incidents associated with children’s folding chairs and stools, including, but not limited to, pinching, finger injuries, and tip-overs due to instability.
The mandatory Safety Standard for Children’s Folding Chairs and Stools incorporates by reference ASTM F2613-19, the voluntary standard, without modification. The Commission published its revised final rule in April 2020, 85 FR 18111 (April 1, 2020). ASTM F2613-19 can be purchased from ASTM International via: www.astm.org.
Please note that although the ASTM F2613 voluntary standard covers both folding and non-folding chairs and stools, only children’s folding chairs and stools are covered under the mandatory safety standard.
The standard includes testing requirements for structural integrity and performance requirements specific to children’s folding chairs and stools, general performance requirements, and labeling requirements.
The standard also includes: (1) a requirement that wooden parts be smooth and free of splinters; (2) a prohibition of hazardous sharp points and edges; (3) small parts limitations; (4) that flammable solids meet the requirements of 16 CFR §1500.3(c)(6)(vi); (5) design requirements to prevent scissoring, shearing, and pinching; (6) folding mechanism and hinge requirements to eliminate crushing, laceration, or pinching hazards; (7) locking mechanism requirements to prevent unexpected or sudden movement or collapse of the product; (8) limitations on clearance along the hinge line between a stationary and moveable portion of the folding chair or stool; (9) limitations on measurements of any circular holes in rigid materials to prevent finger entrapment; (10) requirements that the product remain fully functional and not tip over backwards or sideways when tested for stability; (11) requirements for the permanency of labels and warnings; and (12) requirements that any toy attachments meet applicable toy safety requirements.
Children’s folding chairs and stools are subject to requirements for surface coatings, lead, testing and certification, registration cards, and tracking labels. These requirements are discussed below and at: www.cpsc.gov/BusinessEducation:
- Surface Coating Limit: Children’s folding chairs and stools must not be painted with paint that contains more than 90 ppm (0.009 percent) lead.
- Lead Content Limit: Children’s folding chairs and stools must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Testing and Certification: Children’s folding chairs and stools, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by a CPSC-accepted, third party laboratory for compliance with the Children’s Folding Chairs and Stools Standard (Effective July 6, 2020) and all other applicable children’s product safety rules. Based on that testing, a domestic manufacturer (or importer) of children’s folding chairs and stools must issue a Children's Product Certificate specifying each applicable rule and indicating that the product complies with those rules.
- Product and Outer Package Labeling Requirements: Durable infant or toddler products, such as children’s folding chairs and stools, must be permanently marked with specific labeling information, including tracking labels, on the product and on the packaging.
- Product Registration Card Requirement: In addition, durable infant or toddler products are required to have additional product markings and a product registration card attached to the product. This chart summarizes the specific labeling and registration requirements that durable infant and toddler products must meet.