Portable Hook on Chairs

Federal law requires that portable hook-on chairs comply with the portable hook-on chair standard and  additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

Manufacturers and importers of portable hook-on chairs must certify in a Children's Product Certificate that their portable hook-on chair complies with the standard and additional requirements after the portable hook-on chairs have been tested for compliance by a CPSC-accepted, third party laboratory. These requirements are discussed below and at: www.cpsc.gov/BusinessEducation.

A portable hook-on chair is a seat made expressly to seat and hold children who can sit up on their own.  A portable hook-on chair is usually a legless seat, designed to position the occupant at a table and at an elevation allowing the table top to be used as the feeding surface for the occupant. The hook-on chair is supported solely by the table on which it is mounted.  These chairs are intended for use by children from age 6 months to 36 months, and who weigh no more than 37 pounds (16.8 kilograms). 

Typical hook-on chairs consist of fabric over a lightweight frame, with a device to mount the seat to a support surface, such as a table or counter. Some hook-on chairs fold for easy storage or transport, and some include a removable tray that can be used in conjunction with a table.

The standard seeks to prevent deaths and injuries by preventing falls when the chair detaches from the table or breaks, or when the table and chair tip over together. 

The standard is published in the Code of Federal Regulations at: 16 CFR part 1233. The standard incorporates by reference ASTM F1235-18.

The general requirements from the ASTM standard for portable hook-on chairs cover the following:

• Testing requirements for sharp points;
• Testing requirements for small parts;
• Limits on lead in paint;
• Requirements for wood parts;
• Requirements for latching and locking mechanisms;
• Requirements to prevent scissoring, shearing, and pinching (including during detachment from table support surface);
• Requirements for covering exposed coil springs;
• Size requirements for openings;
• Warning labeling requirements;
• Requirements for protective components; and
• Marking, labeling, and instructional literature requirements.

Additional performance requirements include:

• Chair Drop to test that the hook-on chair does not exhibit any mechanical hazards (sharp points, sharp edges, or small parts) after a drop test has been performed.
• Static Load to test that the hook-on chair is strong enough to support approximately three times the weight of a child expected to be in the seat.
• Seat and Seat Back Disengagement to test that the seat and seat back are strong enough to withstand the forces they will be subject to during use.
• Chair Bounce Test to simulate a child bouncing up and down in the hook-on chair.
• Chair Pull/Push Test to verify that the hook-on chair does not detach from the test surface under a variety of forces and weights.
• Restraint System Performance Requirements and Tests require an active restraint system to secure a child in the seated position in each of the manufacturer’s-recommended use positions and tests that the restraint system and its closing means do not break, separate, or release the occupant when various forces are applied.
• Openings and Passive Crotch Restraint System requirements to require a passive crotch restraint and to reduce the likelihood of children getting injured or dying as a result of sliding through or becoming entrapped in an opening.
• Scissoring, Shearing, and Pinching Disengagement Test intended to reduce the likelihood of children becoming injured due to motion caused by the rotation of a hook-on chair when one side (clamp) detaches from the table.
   

The specific requirements and descriptions of the tests for portable hook-on chairs are found in ASTM F1235-18, which can be purchased from ASTM by visiting: astm.org.

Portable hook-on chairs are subject to requirements for surface coatings, lead content, phthalates, testing and certification, registration cards, and tracking labels. These requirements are discussed below, and at www.cpsc.gov/cpsia:

• Surface Coating: Portable hook-on chairs must not be painted with paint or surface coatings that contain more than 90 ppm (0.009 percent) lead.
• Lead Content: Portable hook-on chairs cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
• Phthalate Content Limits: Plasticized components of portable hook-on chairs 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: Portable hook-on chairs, 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 if there is no domestic manufacturer) of portable hook-on chairs must issue a Children's Product Certificate indicating that the product complies with those rules.
• Product and Outer Package Labeling Requirements: Durable infant or toddler products, such as portable hook-on chairs, 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.

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.