CPSC Consumer Registration Cards for 6 Infant Products Take Effect Dec 29

(As required by the Consumer Product Safety Improvement Act of 2008 (CPSIA), the consumer registration requirements have been in effect for 12 other durable infant and toddler products (cribs, walkers, swings, strollers, etc.) since June 2010.)

Affects Folding Chairs, Changing Tables, Bouncers, Tubs, Slings, Bed Rails

The six products affected by the December 29 registration card requirements include children’s folding chairs, changing tables, infant bouncers, infant bath tubs, bed rails, and infant slings.

Requires Consumer Forms, Permanent Marks, Recordkeeping

This means each domestic manufacturer (in the case of domestic products) or importer (in the case of imported products)¹ of such products manufactured after December 29, 2010 will have to:

Provide consumer forms - provide consumers with a postage-paid registration form with each subject product that meets the format and text requirements of 16 CFR 1130.6 and 1130.7. The form must be attached to the surface of each durable infant or toddler product so that, as a practical matter, the consumer must notice and handle the form after purchasing the product.

• The form must include the manufacturer's or importer's name, the model name and number for the product, and the date of manufacture.
• It must also include an option for consumers to register through the Internet and a statement that the information provided by the consumer will not be used for any purpose other than to facilitate a recall of or safety alert regarding that product.

Permanently mark product - permanently mark each product with the manufacturer's (or importer's) name, and contact information (U.S. address and telephone number, toll free if available), model name and number, and date of manufacture.

• If the manufacturer regularly uses only a model name or a model number, but not both, to identify the product, he/she may provide only the model name or number rather than creating a model name or number for the sole purpose of this requirement.
• If the manufacturer regularly identifies the product by a PIN or other similar identifying number rather than a model number, he/she may provide that identifying number instead of a model number.
• The date must include the month and year of manufacture but can be stated in code.
• A permanent mark is one that can reasonably be expected to remain on the product during the useful life of the product.
• The information must be in English, legible, and in a location that is conspicuous to the consumer.
• The information may be combined with other information marked on the product.

Maintain records for 6 years - maintain for six years a record of registrants for each product manufactured that includes all of the information provided by each registered consumer. This information must be used by the manufacturer or importer to notify the registrant in the event of a voluntary or involuntary recall of, or safety alert regarding, such product. It may not be used for any other purpose.

¹CPSC’s December 2009 final rule specified that while retailers, through contractual agreements, may take over the registration cards and databases, manufacturers and importers are ultimately responsible.

(See ITT’s Online Archives or 12/30/09 news, 09123035, for detailed BP summary of the final rule establishing the durable infant toddler product registration card requirements.)