A durable infant or toddler product is a durable product intended for use, or that may be reasonably expected to be used, by children under the age of 5 years and is one of the following:
- Baby Changing Products
- Bassinets and Cradles
- Bedside Sleepers
- Booster Seats
- Carriages and Strollers
- Children’s Folding Chairs and Stools
- 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
All durable infant or toddler products, regardless of type, must currently meet certain children’s product safety requirements, such as those for lead in surface coatings, lead content, phthalate content (in certain circumstances), mandatory testing at a CPSC-accepted laboratory, certification, registration cards, and tracking labels and other markings. These requirements are detailed more fully below.
In addition, those durable products for which the Commission has issued final regulations must comply with additional safety requirements, which are usually physical and mechanical in nature.
The manufacturer or importer is responsible for testing, certifying, labeling, and adding the registration card requirements to all of these products.
In order to improve recall effectiveness, Congress has required that manufacturers of covered products:
- Provide consumers with a postage-paid product registration card with each product;
- Maintain a record of the names, addresses, e-mail addresses, and other contact information of consumers who register their products; and
- Permanently place the manufacturer/importer, U.S. contact information, model name and number, and the date of manufacture on each durable infant or toddler product.
These requirements are currently in effect and apply to all manufacturers of durable infant and toddler products listed above, regardless of whether a specific children’s product safety rule has been issued by the Commission for their particular product.
Learn more about these product registration requirements.
Durable infant or toddler products are subject to requirements for lead in surface coatings, lead and (in certain circumstances) phthalate content, testing and certification, registration cards, and tracking labels. These requirements are discussed below and at www.cpsc.gov/BusinessEducation:
- Surface Coating Limit: Durable infant or toddler products must not be painted with paint that contains more than 90 ppm (0.009 percent) lead.
- Lead Content Limit: Durable infant or toddler products must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Phthalate Content Limits: Durable infant or toddler products that contain plasticized parts that are designed, marketed, or intended to facilitate sleep or have plasticized components that are designed, marketed, or intended to facilitate eating, must not contain more than 0.1 percent of the following eight specified phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), diisobutyl phthalate (DIBP), di-n-pentyl phthalate (DPENP), di-n-hexyl phthalate (DHEXP), and dicyclohexyl phthalate (DCHP).
- Testing and Certification: Durable infant or toddler products, 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 all applicable children's product safety rules. Based on that testing, a domestic manufacturer (or importer) of a durable infant or toddler product must issue a Children's Product Certificate specifying each applicable safety rule and indicating that the product complies with those rules.
- Product and Outer Package Labeling Requirements: Durable infant or toddler products must be permanently marked with specific labeling information, including tracking labels, on the product and on the packaging. 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. Also please question directly below and see in depth FAQs here.
Yes. And for those durable infant or toddler products for which the Commission has already issued children’s product safety rules, third party testing and certification requirements are also in effect for those rules. In the situation where new rules for durable infant or toddler products are being proposed or passed, the effective enforcement date for third party testing is generally 90 days after the Commission provides procedural notice to the testing laboratories. You should review each individual rule as it is released for precise dates.
Signing up for email alerts will provide you the most up to date information on each new durable infant or toddler product rule.
Previously-conducted testing to a new requirement may be acceptable as the basis for certifying a product as compliant provided that certain guidelines are met. This is called retrospective testing. If the Commission accepts this retrospective testing, the Commission will provide guidance on how a certifier may rely upon the previously conducted testing. CPSC has provided an outline of some of the conditions previously required in the last question on the Third Party Testing FAQ page.
The standards organization that issued the voluntary standard (for this class of products, it is most often ASTM International) must provide official notice to the Commission that the standard has been revised. Thereafter, the revised voluntary standard automatically will be considered to be the new, revised mandatory children’s product safety rule 180 days after notification to the Commission by the standards organization, unless the Commission takes additional action. If, after receiving notification of the revision(s) to the standard—and within 90 days from the date of notification to it—the Commission determines that the proposed revision(s) does not improve the safety of the consumer product covered by the standard, and the Commission notifies the standards organization of its determination, the revisions to the voluntary standard do not take effect, and the applicable mandatory children’s product safety rule remains unchanged.
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Contact the SBO directly: If you’re still not sure and would like further assistance with your product, you may contact the Small Business Ombudsman directly through this contact form or by phone at (888) 531-9070.