Tech Watch: CPSC Issues Safety Standard for Infant Support Cushions
On 4 November 2024, the U.S. Consumer Products Safety Commission (CPSC) issued a Final Rule to establish a consumer product safety standard for infant support cushions (16 CFR 1243). This standard is designed to mitigate hazards, specifically suffocation, entrapment, and falls, associated with infant support cushions.
16 CFR 1243 defines an infant support cushion as “an infant product that is filled with or comprised of resilient material such as foam, fibrous batting, or granular material or with a gel, liquid, or gas, and which is marketed, designed, or intended to support an infant’s weight or any portion of an infant while reclining or in a supine, prone, or recumbent position. This definition includes any removable covers, or slipcovers, sold on or together with an infant support cushion.”
Examples of infant support cushions include:
- head positioner pillows;
- flat baby loungers;
- crib pillows;
- wedge pillows for infants;
- infant sleep positioners, unless regulated as medical devices by the Food and Drug Administration (FDA);
- stuffed toys marketed for use as an infant support cushion;
- infant tummy time or lounging pillows, whether flat or inclined;
- multi-purpose pillows marketed for both nursing and lounging;
- anti-rollover pillows with or without straps that fasten the pillow to the infant;
- infant self-feeding pillows that hold a bottle in front of the face of a reclining or lying infant;
- pads and mats; and
- accessory pillows and other padded accessories, often marketed for use with an infant car seat, stroller, or bouncer, but not sold with that product and therefore not included in the mandatory safety standard for those products.
16 CFR 1243 includes the following:
- General requirements
- Hazardous sharp edges or points
- Small parts
- Lead in paints
- Toys
- Removal of components
- Permanency of labeling and warnings
- Convertible products
- Performance requirements: The rule mandates specific performance requirements to address suffocation, entrapment, and fall risks. These include requirements for:
- Restraint
- Seam strength
- Bounded openings
- Maximum incline angle
- Firmness
- Occupant support firmness
- Sidewall firmness
- Firmness at intersection of sidewall and occupant support surface
- Sidewall angle
- Test methods
- Marking and labeling: Clear and conspicuous warning labels are mandatory. These labels must include warnings against using the product for sleep, on elevated surfaces, and with soft bedding. Labels must also be present on slipcovers sold with the product.
The Final Rule will become effective on 5 May 2025. To comply with the Consumer Product Safety Act, all infant support cushions manufactured on or after 5 May 2025, must undergo testing at a CPSC-accepted third-party lab for certification of children's products, as outlined in the 16 CFR 1110 rule. Additionally, infant support cushion manufacturers must provide a product registration card with each infant support cushion sold. This requirement stems from the amendment to 16 CFR Part 1130, which identifies infant support cushions as durable infant or toddler products subject to mandatory registration.
For questions and additional information, please contact Dr. Pratik Ichhaporia
(Pratik.ichhaporia@cpt.eurofinsus.com, +1-669-837-2257) or David Hong (David.Hong@cpt.eurofinscn.com)