Infant Support Cushions FAQs
The regulation is intended to reduce the risk of death and injury from hazards associated with infant support cushions, such as suffocation, entrapment, and fall hazards.
The regulation was originally published at 89 FR 87467 and codified at 16 C.F.R. part 1243.
More information is available on our infant support cushions business guidance page.
An infant support cushion is defined as an infant product that is filled with or comprised of resilient material such as foam, fibrous batting, or granular material or with a gel, liquid, or gas, and which is marketed, designed, or intended to support an infant’s weight or any portion of an infant while reclining or in a supine, prone, or recumbent position, including any removable covers, or slipcovers, sold on or together with such a product.
Examples of infant support cushions include infant positioners (product intended to help keep an infant in a particular position while supine or prone), nursing pillows with a dual use for lounging, infant loungers (infant support cushion with a raised perimeter, a recess, or other area that provides a place for an infant to recline or to be in a supine, prone, or recumbent position), and infant props or cushions used to support an infant.
The regulation excludes products that are subject to another durable infant or toddler product standard as listed at 16 CFR § 1130.2(a), except nursing pillows that also meet the definition of an infant lounger.
Please note, the infant support cushions rule does not affect or amend the existing infant pillow ban. As such, certain infant pillows are still considered banned hazardous substances per 16 CFR § 1500.18(a)(16).
The requirements for infant support cushions are as follows:
- General requirements
- Hazardous sharp edges or points – 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
- Lead in paint – see also our lead in paint business guidance page
- Toys – any toy accessories must meet the applicable requirements for children’s toys
- Removable of components
- Permanency of labels and warnings
- Convertible products
- Performance requirements
- Restraint
- Infant support cushions are prohibited from having restraints
- Seam strength
- Seams must withstand 15 lb. of force applied evenly over 5 seconds and maintained for an additional 10 seconds
- Bounded openings
- Bounded openings that allow the passage of the small head probe must also allow passage of the large head probe
- Maximum incline angle
- Incline angle must not exceed 10°
- Firmness
- Force to displace 1 inch of the occupant support surface, sidewall, and intersection of the sidewall and occupant support surface using the 3-inch diameter head probe must exceed 10.0 N
- Sidewall angle
- Infant support cushions with a sidewall must have a sidewall angle greater than 90°
- Restraint
If the portable changing pad meets the definition of a baby changing product, it is subject to 16 C.F.R. part 1235. Since the definition of “infant support cushion” excludes products that are already subject to an existing infant durable of infant toddler rule, such products would not be subject to the regulation for infant support cushions at 16 C.F.R. part 1243.
Portable changing pads that fall outside of the scope for baby changing products but include marketing or are intended for lounging purposes would meet the definition of “infant support cushion” and thus be subject to the regulation for infant support cushions.
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 with 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 with 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.