Federal law requires that infant bath tubs comply with the mandatory Safety Standard for Infant Bath Tubs, 16 C.F.R. Part 1234 (Effective October 2, 2017), 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.
Where can I find the standard for infant bath tubs?
The mandatory Safety Standard for Infant Bath Tubs incorporates by reference ASTM F2670-17, the voluntary standard, without modification. The Commission published its final rule in March 2017, 82 Fed. Reg. 15615 (March 30, 2017). ASTM F2670-17, the Standard Consumer Safety Specification for Infant Bath Tubs, can be purchased from ASTM International.
What is an infant bath tub?
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 3.1.2 of ASTM F2670-17). The infant bath tub performance standard specifically excludes from the scope of the Standard “products commonly known as bath slings, typically made of fabric or mesh” (Paragraph 1.1).
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 F2670-17 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.”
What is the purpose of the infant bath tubs Standard?
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.
What are the requirements for 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.
What are the additional requirements for infant bath tubs required by the CPSIA?
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 (Effective October 2, 2017) 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.
Where can I find additional information?
For more information on the requirements for soft infant and toddler carriers, contact the U.S. Consumer Product Safety Commission:
- Visit our Regulatory Robot, designed to guide you through CPSC’s product safety requirements.
- Contract our Office of Compliance (for specific enforcement inquiries): e-mail: firstname.lastname@example.org; telephone: (301) 504-7520.
- Ask our Small Business Ombudsman (for general assistance understanding and complying with CPSC regulations): e-mail: Please use our Contact Form, which is the best way to get a fast response; telephone: (888) 531-9070.
This communication has been prepared for general informational purposes only. This summary document does not, and is not intended to, constitute legal advice nor does it replace or supersede a manufacturer’s obligations to comply with all applicable laws, regulations, standards, or bans enforced by CPSC. This communication has not been reviewed or approved by the Commission, and does not necessarily represent their views. Any views expressed in this communication may be changed or superseded by the Commission.