Notes on Regulations Governing the Export of Children's Products
Background
Mandatory regulations concerning children's products in the US market are primarily divided into two parts:
1. Consumer Product Safety Improvement Act of 2008 (CPSIA) and 16CFR provide relevant requirements and standards for children's products. Each 16CFR regulation incorporates all or most corresponding ASTM voluntary standards.
2. California Proposition 65 (CP 65) (formerly known as the Safe Drinking Water and Toxic Enforcement Act of 1986) was originally a proposal to protect drinking water sources in California. Now it has become a statute regulating hazardous chemicals in California. The statute constantly expands its coverage over hazardous substances in products through in CP 65. So far, it has set restrictions on hundreds of chemicals. Only products conforming to CP 65 can be sold in California.
Mandatory regulations concerning children's school supplies in the EU are as follows:
1. 2001/95/EC General Product Safety Directive (GPSD), which require products to be safe;
2. Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), which establish a European Chemicals Agency. Products for different purposes are subject to different restrictions on certain substances. If the concentration of an SVHC in a product exceeds the limit, the manufacturer or importer shall give information about the SVHC; and
3. Stockholm Convention, which targets Persistent Organic Pollutants (POPs), a class of environmental pollutants. POPs are mainly pesticides or industrial additives containing halogens or heterocycles, which have a cumulative toxicity and pose a threat to the environment and our health.
Scope
Children's products are consumer products, except toys and school supplies, designed for children below 14 years of age, including strollers, cradles, teethers, cribs, and high chairs.
Regulations
The US
Cradles
16CFR1218 + ASTM F2194-16e1 Standard Consumer Safety Specification for Bassinets and Cradles
Key regulatory points: internal height, mattress dimensions, flatness and stability.
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
Strollers
16CFR1227 + ASTM F833-19 Standard consumer safety performance specification for carriages and strollers
Key regulatory points: belt position, shear and squeeze points of 2D fold strollers, front armrest stuffing, stability and brake performance.
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
High chairs
16CFR1237 + ASTMF2640-18 Standard consumer safety performance specification for booster seats
Key regulatory points: belt effectiveness and seat surface impact strength
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
Cribs
16 CFR 1219-16e1 + ASTM F1169-19 Standard Specification or Full-Size Baby Crib
Key regulatory points: internal height, interior dimensions, fasteners' resistance to loosening, strength, and high-frequency test.
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
-16 CFR1220 + ASTM F406-19 Standard Consumer Safety Specification for Non-Full-Size Baby Cribs
Key regulatory points: internal height, interior dimensions, fasteners' resistance to loosening, strength, high-frequency test, and mattress.
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
16 CFR 1217 + ASTM F 1821-19e1 Standard Consumer Safety Specification for Toddler Beds
Key regulatory points: bedside rail height and strength, bed strength
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
-16 CFR 1222 + ASTM F2906-13 (2019) Standard Consumer Safety Specification for Bedside Sleepers
Key regulatory points: height of the lower side, joint strength and distance between the bedside sleeper and the parents' bed.
CPSIA 101 Lead
CP 65
CPSIA 103 Tracking label
CPSIA 104 Registration card
CPSIA 108 Phthalates [DBP/BBP/DEHP/DIBP/DPENP/DHEXP (DnHP)/DCHP/DINP]
The EU
Cradles:
EN1130-2019
Annex XVII of REACH
POPs
Key regulatory points: side height, stability, and bed floor flatness.
Strollers:
EN1888-1: 2018/EN1888-2: 2018
Annex XVII of REACH
POPs
Key regulatory points: belt effectiveness and strength, stability, dynamic durability, handgrip strength, impact and wheel strength.
High chairs:
EN16120: 2012 + A2: 2016 + AC: 2018 Child use and care articles - Chair mounted seat
Annex XVII of REACH
POPs
Key regulatory points: belts, joint strength, and side protection height.
Cribs:
EN 716-2017 + AC: 2019; EN 716-2: 2017 Furniture - Children's cots and folding cots for domestic use - Part 1: Safety requirements and Part 2: Test method
Annex XVII of REACH
POPs
Key regulatory points: stability, locking mechanism, risk of hooking, strength, and durability.
EN 1130: 2019 - Children's furniture - Cribs - Safety requirements and test methods
Annex XVII of REACH
POPs
Key regulatory points: height of the lower side, joint strength and distance between the crib and the parents' bed, locking mechanism, and bed floor flatness.
BS 8509: 2008 + A1: 2011 Children’s beds for domestic use- Safety requirements and test methods
Annex XVII of REACH
POPs
Key regulatory points: side rail height and strength, side strength and durability, and risk of hanging.
Legal Basis
For more information about the regulations and standards for children's products, please refer to:
Note: The above information does not constitute any legal advice and shall not be deemed or represent the legal opinion or conclusion of the regulatory body. Further, we do not undertake or warrant that the information represents the latest laws and regulations. For specific information, consult the competent authority, law firms, or third-party certification/testing/consulting companies in the target country or region.
AliExpress
August 31, 2020