Federal law requires that infant bath tubs comply with the mandatory Safety Standard for Infant Bath Tubs, 16 C.F.R. Part 1234, and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).
Manufacturers and importers of infant bath tubs must certify in a Children's Product Certificate (CPC) that their infant bath tubs comply with the mandatory standard and any additional CPSIA requirements after the infant bath tubs have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are discussed below and at: www.cpsc.gov/BusinessEducation.
The mandatory Safety Standard for Infant Bath Tubs incorporates by reference ASTM F2670-22, without modification. ASTM F2670-22, the Standard Consumer Safety Specification for Infant Bath Tubs, can be purchased from ASTM International.
An “infant bath tub” is a “tub, enclosure, or other similar product intended to hold water and be placed into an adult bath tub, sink, or on top of other surfaces to provide support or containment, or both, for an infant in a reclining, sitting, or standing position during bathing by a caregiver” (Paragraph 3.1.4 of ASTM F2670-22).
Infant bath tubs within the scope of the Standard include products of various designs, such as bucket-style tubs that support a child sitting upright, tubs with an inclined seat for infants too young to sit unsupported, inflatable tubs, folding tubs, and tubs with spa features, such as handheld shower attachments and even whirlpool settings. Paragraph 6.1 of ASTM F2670-22 permits infant bath tubs to have “a permanent or removable passive crotch restraint as part of their design,” but does not permit “any additional restraint system(s) which requires action on the part of the caregiver to secure or release the restraint.”
The Standard seeks to minimize the risk of deaths and injuries associated with the use of infant bath tubs, including incidents related to infant drownings and near-drownings and situations involving the collapse of infant bath tubs.
The Standard has stringent requirements for the overall integrity and operation of the infant bath tub, along with marking, labeling, and instructional literature requirements. The performance requirements address restraints, protective component integrity, and structural and attachment integrity.
Infant bath tubs 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: Infant bath tubs must not be painted with paint that contains more than 90 ppm (0.009 percent) lead.
- Lead Content Limit: Infant bath tubs must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Testing and Certification: As a product designed or intended primarily for children 12 years of age or younger, infant bath tubs must be tested by a CPSC-accepted, third party laboratory for compliance with the infant bath tubs Standard and all other applicable children’s product safety rules. Based on that testing, a domestic manufacturer (or importer) of infant bath tubs 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 infant bath tubs, 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.