Infant Bath Seats
Federal law requires that infant bath seats comply with the infant bath seat standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).
Manufacturers and importers of infant bath seats must certify in a Children's Product Certificate that the infant bath seat complies with the standard and the additional requirements after the infant bath seats have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are discussed below and at www.cpsc.gov/BusinessEducation.
An infant bath seat is used in a bath tub, sink, or similar bathing enclosure and provides support, at a minimum, to the front and back of a seated infant during bathing by a caregiver. This does not include products designed or intended to retain water for bathing, such as infant bath tubs.
The standard seeks to prevent deaths and injuries, particularly drowning and near-drownings, when a bath seat is used with an infant.
The standard is published in the Code of Federal Regulations at 16 CFR Part 1215. The standard incorporates by reference ASTM F1967-19.
The principal performance requirements from the ASTM standard for bath seats are:
- requirements for latching and locking mechanisms;
- requirements to prevent scissoring, shearing, and pinching;
- entrapment testing for accessible holes and openings;
- torque/tension testing for graspable components;
- a requirement that warning labels be permanent;
- a test for stability, performed on a test platform containing both a slip-resistant surface and a smooth surface, to test whether the bath seat may tip over during use;
- requirements for a passive crotch restraint, to prevent a child from sliding through front or sides of the seat;
- a static load test to test whether the bath seat may break or become damaged during use;
- a requirement that suction cups (if used) adhere to the bath seat and the surface;
- a leg opening requirement to prevent children from sliding through these openings;
- a leg opening requirement restricting the expansiveness of the seating area to prevent the child from slumping and becoming entrapped in a reclined position;
- requirements for warning labels and an instruction manual;
- a requirement to limit the allowable tilt angle of the bath seat during the stability test; and
- a requirement that during testing, the test solution be applied to all areas where the product makes contact with the test platform.
The specific requirements and descriptions of the tests for infant bath seats are in ASTM F1967-19, which can be purchased from ASTM.
Infant bath seats are subject to requirements for surface coatings, lead content, small parts, testing and certification, registration cards, and tracking labels. These requirements are discussed below and at www.cpsc.gov/cpsia:
- Surface Coating: Infant bath seats may not be painted with paint that contains more than 0.009 percent lead.
- Lead Content: Infant bath seats cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Testing and Certification: Infant bath seats, 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 applicable children's product safety rules. Based on that testing, a domestic manufacturer (or importer) of infant bath seats must issue a Children's Product Certificate indicating that the product complies with those rules.
- Registration Cards: Each manufacturer of an infant bath seat must (1) provide a postage-paid consumer registration form with each product and (2) keep records of consumers who register their products with the manufacturer. In addition, manufacturer's add permanent markings to the product that state (3) the manufacturer's name and contact information, (4) the model name and number, and (5) the date of manufacture permanently on each such product.
- Tracking Labels: Infant bath seats must have a tracking label or other distinguishing permanent mark affixed to the product and its packaging. The tracking label shall be a permanent distinguishing mark on the product and its packaging, to the extent practicable, and must contain certain basic information, including the (1) name of the manufacturer or private label, (2) the location and date of manufacture, and (3) cohort information, such as a batch or run number.
To the extent that the information required to be marked on the product (by the tracking label requirement and the registration card rule) is duplicative, you may combine the markings on the product to satisfy both requirements. Note that the tracking label requirement must also be marked on the product's packaging.