Baby carriers manufactured and imported in the United States are covered by mandatory safety standards, substance restrictions, labeling, certification, and lab testing requirements. In this guide, we cover CPSIA, ASTM standards, and other compliance requirements applicable to several types of baby carriers – including soft infant carriers, frame child carriers, and sling carriers.
CPSIA regulates all children’s products sold or distributed in the United States. For baby carriers like soft infant carriers, frame child carriers, and sling carriers, CPSIA mandates specific ASTM standards and additional requirements in order to ensure the safety of the products.
Before we start to explain more in detail the CPSIA requirements, including the different ASTM standards for different types of infant carriers, here is a brief summary of what we cover:
- ASTM F2236
- ASTM F2549
- ASTM F2907
- Children’s Product Certificate (CPC)
- Consumer Registration Card
- Test Report
- CPSIA Tracking Label
ASTM F2236: Standard Consumer Safety Specification for Soft Infant and Toddler Carriers
According to the definition of CPSIA, a soft infant and toddler carrier is a sewn fabric construction designed to carry infants or toddlers.
CPSIA adopts ASTM F2236 as the main standard for specific performance requirements, test methods, and labeling requirements for soft infant and toddler carriers in order to reduce the risks of incidents to an infant from normal use and reasonable abuse of the products.
ASTM F2236 describes that soft infant and toddler carriers are products that are usually wrapped around the neck, shoulder, or the back of the caregivers in an upright position in order to support the weight of the children, which generally between 7 and 45 lb (3.2 and 22 kg).
ASTM F2236 establishes substance concentration requirement for soft infant and toddler carriers as follow:
ASTM F2236 requires that soft infant and toddler carriers must comply with CFR Title 16 lead content requirements for paint or surface coating, which is 90 parts per million (ppm). Also, the accessible parts of the product shall not contain more than 100 ppm of total lead content.
Some parts or components of the soft infant carriers could contain plasticized parts, such as the buckles, or the removable plastic toys. These plastic parts might be treated with phthalates in order to enhance flexibility and tactility. ASTM F2236 requires that such parts shall not contain more than 0.1% of the following 8 kinds of phthalates:
ASTM F2236 establishes the safety requirements from the perspective of the mechanical and physical properties of the infant’s carriers. Below are examples of requirements.
Fastener Strength and Strap Retention Performance
The fastener shall not break or disengage, and adjustable elements in straps shall not slip more than a given value when tested with leg openings test and dynamic and static load tests. This is to ensure the carrier is able to fully support the children under moving or static circumstances.
This standard requires that soft infant carriers shall not have any small parts as defined in 16 CFR 1501, which could cause choking or suffocation hazards to young children.
Hazardous Sharp Points or Edges
Sharp points and edges defined by 16 CFR 1500.48 and 1500.49 are prohibited since they present a potential risk of injury by puncture or laceration.
Latching and Locking Mechanisms
Soft infant carriers with latching and locking mechanisms must remain in the manufacturers’ recommended use position, which is a safe position to hold the infants and avoid their falling due to moving or slipping.
Toy accessories that are attached to soft infant carriers, such as rattle toys, plush animal toys, and chew beads must meet applicable requirements of ASTM F963 Standard Consumer Safety Specification for Toy Safety.
Since soft infant carriers are made of fabrics, ASTM F2236 requires that such products must conform to the flammability requirements set in 16 CFR part 1610 Standard for the Flammability of Clothing Textiles, unless the fabric materials of the soft infant carriers belong to Class I fabric, which are:
a. Plain surface fabrics of any fiber content weighing more than 2.6 ounces per square yard
b. Fabric made of acrylic, modacrylic, nylon, olefin, polyester, and wool; or the combination of these materials.
Warning Label Requirements
ASTM F2236 requires that each soft infant carrier shall be labeled with warning statements informing users of the fall hazards and suffocation hazards that could be caused by the product.
The warning statements shall be articulate, permanent, and conspicuous affixing on the product so that the users can read and understand the hazard quickly.
The warning statement shall describe the fall hazard and suffocation hazards clearly with conspicuous safety alert symbol “⚠” and the uppercase signal word “WARNING” in size no less than 0.2 inches (5mm) high.
Here’s an example of a warning label:
FALL AND SUFFOCATION HAZARD
FALL HAZARD – Infants can fall through a wide leg opening or out of the carrier.
- Adjust leg openings to fit baby’s legs snugly.
- Before each use, make sure all are secure.
- Take special care when leaning or walking.
- Never bend at the waist; bend at knees.
- Only use this carrier for children between ___lb. and ___lb.
SUFFOCATION HAZARD – Infants under 4 months can suffocate in this product if the face is pressed tightly against your body.
- Do not strap infants too tight against your body.
- Allow room for head movement.
- Keep infant’s face free from obstructions at all times.
ASTM F2549: Standard Consumer Safety Specification for Frame Child Carriers
Frame child carriers are, as defined by CPSIA, sewn fabric construction on a tubular metal or other frames that are intended to carry a child in an upright position on the back of the caregiver. Frame carriers are designed to carry children weighing between 16 pounds and 50 pounds.
Frame child carriers have a resemblance in appearance to hiking/mountaineering backpacks and are therefore favored by parents in outdoor environments.
CPSIA incorporates the ASTM F2549 into 16 CFR Part 1230 as the specification, performance, and test requirement mandatory standard for frame child carriers.
Frame child carriers shall comply with the same substance restriction requirements laid down for soft carriers (see the previous section of this article), including restrictions on
ASTM F2549 establishes a set of requirements regarding specification, mechanical performance, and other safety properties for frame child carriers. Below is a brief introduction to some of these requirements:
This standard requires that soft infant carriers shall not contain any small parts defined in 16 CFR 1501 in order to prevent choking or suffocation hazards.
Hazardous Sharp Points or Edges
Frame child carriers shall not have sharp points or edges as determined by the 16 CFR 1500.48 and 1500.49 in order to prevent puncture or laceration to children.
Wooden parts of frame child carriers shall be smooth and have no splinters.
Exposed Coil Springs
Exposed coil springs that are accessible to the child shall be covered or designed to prevent injury.
Frame infant carriers that are made with or contain part of fabrics shall comply with applicable requirements set by the Flammability Fabrics Act. Unless the items are made with exempted fabrics, such as acrylic, modacrylic, nylon, olefin, polyester, and wool or the combination of these materials.
Warning Labeling Requirements
ASTM F2549 mandates that warning labels be permanently and conspicuously displayed on the products. The warning label should address at least the following messages:
a. Avoid serious injury from falling or sliding out. Always use a child retention system.
b. Do not use a carrier if a child cannot sit upright unassisted.
c. Do not place the carrier on countertops, tables, or other elevated surfaces.
ASTM F2907: Standard Consumer Safety Specification for Sling Carriers
CPSIA defines a sling carrier as a fabric or sewn fabric construction supported by the caregiver’s torso in order to carry up to two children in an upright or reclined position. Sling carriers are usually designed to carry infants of full-term birth to 35 lb (15.9 kg). The weighing capacity of the sling carriers could vary according to the individual product.
CPSIA incorporates ASTM F2907 into 16 CFR Part 1228 as the mandatory standard for sling carriers.
As for soft carriers and frame child carriers, also sling carriers shall comply with the same substance restrictions, including restrictions on the following substances:
Performance requirements specific to sling carriers set out by ASTM F2907 include the following:
a. Structural Integrity – the structure of sling carriers must be intact and prevent failures
b. Prohibition of hazardous sharp points or edges
c. Prohibition of small parts
Fabrics that are used to produce sling carriers must comply with the applicable requirements set by the Fabric Flammability Act.
Warning Labeling Requirements
The label shall include a statement for suffocation hazard and fall hazard warning.
Below we list the documents required by CPSIA for baby carriers manufactured or imported in the US.
Children’s Product Certificate (CPC)
Let me know if something it’s not clear, and I can explain again! of products that are intended to use by children, including frame carriers, must issue a copy of the Children’s Product Certificate (CPC), which demonstrates the applicable standards and requirements such products comply with.
A CPC shall include the following information:
a. Product identity
b. Manufacturers or importers information (i.e. Company name and address in the US, e-mail, phone)
c. Contact information of the person with access to the test report (name, address, e-mail, phone)
d. Date and location of manufacture
e. Test date (month, year)
f. Applicable ASTM and CPSC standards (i.e. ASTM F2236)
g. CPSC accepted third-party lab testing company information
Consumer Registration Card
Every durable children’s product, which is children’s product that has an expected service life of more than 3 years under reasonable use, should be affixed with a Consumer Registration Card at the retail stage.
The Consumer Registration Card is set up to improve recall effectiveness of products in cases of emergency and shall include the manufacturer or importer’s business information such as:
- Company name
- Company postal address
- Company contact number
- Company email address
- Model name and number
- Date of manufacture
Baby carriers must be tested in accordance with applicable standards before they can be sold in the United States.
Note that these tests must be conducted by CPSC-accredited labs.
CPSIA Tracking Label
Products that are marketed to children below the age of 12 are required to bear a CPSIA tracking label, which contains traceability information that enables the fast and accurate tracking of defective products. Below is an example of CPSIA tracking label:
- MICKMOUE Products LLC
- Date: June 2021
- Location: Guangzhou, China
- Batch number: KCE-31429-CHN
- All new materials
Amazon requires that children’s products listed in its platform must comply with applicable federal and state regulations.
Amazon has devoted specific pages for soft infant and toddler carriers, frame child carriers, and sling carriers to introduce specific requirements for these products:
a. Soft infant and toddler carriers (ASTM F2236 and CPSIA lead and phthalates requirements)
b. Frame child carriers (ASTM F2549 and CPSIA lead and phthalates requirements)
c. Sling carriers (ASTM F2907 and CPSIA lead and phthalates requirements)
When listing either of these products, sellers might need to submit the following information to amazon when being requested:
a. Seller’s company name (if any) and seller ID
b. Seller’s contact information: email address and phone number
c. Listed product identity
d. Product images for listed products displaying (Safety information and registration card, compliance markings (including tracking label), hazard warnings)
e. Product instructions and/or manuals
f. A Children’s Product Certificate (CPC)
g. Qualified test reports issued by a CPSC-accepted lab
Amazon has the right to remove or suspend the product listing or take legal actions if sellers do not submit this information by the requested deadline.
Third-party lab testing is mandatory when importing and manufacturing all products covered by CPSIA, including baby carriers. Further, only test reports issued by CPSC accepted labs are valid.
Baby carrier lab testing tends to cover the following:
- Chemicals testing
- Heavy metals testing
- Physical/mechanical properties
We recommend that you let the lab decides which tests apply to your product.
Baby carriers manufactured outside the United States are not designed to comply with relevant ASTM standards in mind. Further, materials used to make baby carriers can also contain excessive amounts of restricted substances – such as lead, and Phthalates.
Some baby carriers may also be unsafe from a design and construction perspective.
Manufacturers or importers must therefore take a hands-on approach when importing baby carriers from China, Vietnam, or elsewhere. As said, lab testing is mandatory, but you must also provide a ready-made tracking label to your supplier to ensure that the product is correctly labeled.