22 Apr

FAQ: Compliance for Consumers by The BCIA

This article, written by Linnea Catalan and re-posted with permission, was originally shared by the Baby Carrier Industry Alliance. You can find it posted here.

There’s a lot of confusion around baby carrier compliance. Here’s the rundown on what it all means, what to look for and what to avoid when you are shopping for a baby carrier. Much of this information is specific to the US market. Have a question about compliance in another country? Contact us and we’ll do our best to add it to our FAQ.

sewing

Stewed Rhubarb Handmade hemming wraps

Q: Why is compliance important?

A: Primarily because it protects consumers. Many countries have laws that regulate lead and other chemical limits, and flammability. There are often standards to be tested to in order to ensure that a product can pass mechanical testing, and does not pose a choking, pinching or fall hazard. Regulations ensure that products come with appropriate labeling, care information and proper use instructions.

A company who is compliant with current regulations is illustrating a commitment to the industry, and to a best practice business model. If a company is willing to break the law regarding regulations, where else are they willing to cut corners?

Q: How do I know if a product is compliant?

A: In the US, the CPSC (Consumer Product Safety Commission) outlines current regulations under the CPSIA (Consumer Product Safety Improvement Act). These regulations are legal requirements. There are lots of requirements that you won’t see as a customer that have to do with record keeping and testing plans but there are a few things that you should look for. To break it down simply, a consumer is looking for three things:

Proper labeling

Product registration

An indication that the product has been tested to any applicable safety standards

Q: What is a product registration card and do I need to fill it out?

A: This is a perforated postcard that includes the manufacturer information, product information (product name and model number) and is postage-paid. It should also include a website or email address to register online.

In the event of a recall or incident, manufacturers will be able to access customer data tied to a particular product quickly. It’s meant to streamline the process should a recall, even a minor one, ever take place. Please register your products! Many customers don’t, and this makes more work for manufacturers, and leaves you uninformed for longer if there should be a recall.

Q: How should a baby carrier be labeled?

A: Carriers require a few different labels, and we have outlined the required information below.

Permanent tracking label

This is a label (or labels) outlining manufacturer details (address or phone number, website), where a product was made as well as a product number and date of manufacture. If your product had special packaging, this info should be on the packaging as well.

Permanent tracking labels are one of the most useful regulations in the US. In the event of a recall or incident, it allows a manufacturer to pinpoint exactly the products that might be affected. It also tells you, as the customer, when your product was made, which can be very useful for determining how much life a product might have left. This requirement has been in place since January 2011, so if you find an untagged sling at a yard sale, know that it might well be over 4-5 years old and maybe it’s not quite the bargain it seems.

Care label

This is a requirement under the Textile Act. One of the tags should outline fiber content, product origin and care instructions so you know what your product is made of, where it came from and how to wash it. You can see a similar tag inside almost any other article of clothing.

Q: What is this giant warning label doing on my carrier?

The CPSC will often make testing to an international standard a mandatory requirement. Currently, all soft infant and toddler carriers (front packs, mei tais, soft structured carriers) made or imported after Sept 28, 2014 must pass the requirements outlined in ASTM F2236. That standard outlines things like:

-required mechanical/physical testing to the weight specified on the carrier label

-choking and strangulation hazards

-permanent warning label

-mandatory usage instructions

All carriers currently being produced should comply with the ASTM F2236 standard requirements in addition to the previously mentioned requirements (product registration etc).

Q: What about slings and wraps?

ASTM  F2907 is the international standard used in the US for wraps, slings, pouches, carrier shirts and many hybrid carriers. At this time, the sling standard is voluntary. We expect to see it become mandatory in the US in 2016.

Many manufacturers are being proactive and testing to this standard while it is still voluntary. Others are starting the process with proper labeling and instructions, so don’t be surprised if you see warning labels and other small changes to your favourite brands.

wrap roll

Joy and Joe finished woven wraps

 

 

Q: Can I still have a wrap converted into a ring sling/mei tai/carrier of my choice?

A: Yes, and no. Any of the soft carrier conversion manufacturers who are still making carriers out of wrap fabric should have come up with a testing plan. Unless the wrap layer is only a decorative panel on the outside, expect that converters are only able to work with new wraps in a fabric/blend that they have tested their product model to at an independent 3rd party lab. The manufacturer should be able to explain what their process is.

Slings can still be converted from your own supplied fabric until testing to the standard becomes mandatory, likely in 2016. Some manufacturers may preemptively begin changing their production models before this date in anticipation of the upcoming changes.

sling rings

The importance of quality, tested materials cannot be overstated. Sling Rings.

 

IMG_20150222_215403

Sewfunky ring slings

 

 

Q: Are accessories, inserts, suck pads etc. tested or regulated?

A: There are no official regulations specifically for accessories. General children’s product requirements will apply. Do not assume that an insert, or suck pads will have been tested with your carrier, and exercise caution with aftermarket products. For more information, see our article on accessories here.

Q: Can I (cinch the base/use a receiving blanket/use another manufacturer’s insert) with my carrier?

A: If the carrier you are using recommends using an insert for a proper fit it is strongly advised that you follow the manufacturer guidelines. The insert is designed to support a small baby at the sides to prevent slumping in addition to boosting baby up to kissable height. It is difficult to predict if another manufacturer’s insert will fit your carrier appropriately or if DIY adjustments (ex. a rolled up receiving blanket) will be suitable.

Q: I really only want to buy one carrier. Can I buy a ‘toddler sized’ carrier and my child will grow into it?

A: No, you really can’t. Baby carriers, like jogging strollers and carseats really should fit your child properly and securely. This is especially critical in the first 4 months of life when babies require optimum stability and support. A too big carrier can present a potential slumping, falling or asphyxiation hazard. Buy the carrier that meets your needs now, not where you think you’ll be in 2 years!

Q: I want to make a carrier or sling for myself. Does it need to be compliant?

A: Products made for yourself are just that, made for yourself. These do not need to be tagged, labeled or tracked.

Q: I’d like to sell my DIY carrier after I’m done with it. What do I need to know?

A: That is a trickier question. As soon as you sell a product, even for the cost of materials, you are entering into commerce and are in essence becoming a manufacturer with all the risks and responsibilities that comes with (the CPSC really doesn’t care if you are making a profit or not!) If you are making a product for yourself, make a product for yourself. If you want to set up shop, do it legitimately for your own protection as well as that of your customers.

Q: If I hem or shorten slings and wraps does this make me a manufacturer?

A: No. Hemming a pair of pants doesn’t make you a pants manufacturer, it makes you a seamstress or tailor. Shortening a product or making minor repairs and alterations does not make you a manufacturer.

A note about altering or customizing carriers- in most instances this will void any warranty from the manufacturer so proceed with caution. Some alterations (ie. covering a carrier panel with a slipcover, dyeing a carrier) can make carrier wear and tear harder to spot or can potentially shorten the lifespan of a carrier. It’s always best practice to look your carrier over thoroughly on a regular basis.

Q: What about the second hand market? Do those carriers have to be compliant too?

A: The second hand market is not exempt from regulations. The CPSC resale/thrift store guide can take you through the ins and outs:

http://www.cpsc.gov/en/Business–Manufacturing/Business-Education/ResaleThrift-Stores-Information-Center/

Technically, non-compliant products are not to be resold. It is definitely illegal to resell or donate a recalled product, so do a search on http://www.cpsc.gov/Recalls/ to see if your product has been recalled first. Reselling includes personal sales, auctions, yard sales, consignment stores and secondhand shops.

Q: I found a cheap carrier on the internet, is it safe?

A: Impossible to say. Following the guidelines outlined above will give you a place to start in determining safety. If something seems too good to be true, it probably is. Compliance, safety and suitable materials come at a cost. Counterfeit and knock-off copies of well known carriers are untested, unknown, and often of subpar construction. There are lots of places to save money when buying baby gear, but buying the cheapest carrier possible off the internet shouldn’t be one of those places. For more information about fakes and how to spot them:

http://babycarrierindustryalliance.org/2013/02/fake-carriers-warning/

fergo

Buyer beware- if the price seems too good to be true, it often is.

 

 

Q: Can/should I report noncompliance? How do I do that? What about unsafe carriers?

A: Great question! Anytime the manufacturer of a product becomes aware that their product is not in compliance with a mandatory standard or they receive information that indicates to them that their product may pose a substantial hazard they must by law report to the CPSC themselves. However, the regulations themselves are complex and confusing. So if a consumer believes that a product is not in compliance with a mandatory standard or may pose a substantial product hazard, he or she should always contact the manufacturer first to determine the facts and scope of the issue. The product may be subject to an exemption contained in the regulations or the issue of concern may be the subject of a voluntary standard but not a mandatory standard.

Since the agency’s inception, consumers have also been invited to call the CPSC’s hotline if they have an experience where they are concerned that a product creates a substantial hazard. More recently, consumers can report concerns regarding product safety on CPSC’s public database at SaferProducts.gov. Consumers can also search SaferProducts.gov to search for past recalls.

Of course, the safety of all children being carried in these products is the top concern, so something that poses a serious risk to safety is certainly reportable to either the manufacturer or to the agency.

Q: Are there rules about how a carrier should be sewn? What is “sewing compliance”?

A: There is no such thing as sewing compliance. There are certainly industry best practices and indications of quality workmanship, but there are no hard and fast rules determining how a carrier must be constructed. A carrier which has passed testing to an international standard (like ASTM F2236 or F2907 or to the European standards EN13209 or TR16512) has undergone rigorous testing to determine its safety for market. The standard does not dictate how a carrier is constructed, only how well it must perform under the testing process.

colourfast testing

Fabric is tested for colorfastness at an accredited laboratory.

 

OLYMPUS DIGITAL CAMERA

Warning label guidelines are very specific.

 

 

Q: How does the BCIA (Baby Carrier Industry Alliance) fit into the compliance process?

A: The BCIA is a non-profit trade organization that represents manufacturers, educators and retailers who work in the industry. We promote the growth of the industry, help our members navigate compliance issues and work together under a common voice to achieve things like public safety campaigns, work on the regulatory standards and encourage best practice.

The BCIA is not a certifying or governing body. There is no such thing as ‘BCIA Certified’ or ‘BCIA Compliant’. We do expect our members to adhere to our code of conduct and maintain industry best practices but we are not regulators or bound by duty to report. Regulations in the US are dictated by the CPSC under CPSIA.

Q: If I buy a carrier from overseas, does it have to be compliant?

A: It is expected that all carriers imported into the US are compliant with current regulations. Some overseas manufacturers may choose to work with a US-based retailer or distributor in order to share compliance responsibilities. Non-compliant product may be seized, destroyed, and/or excluded from the US at the point of entry (via Customs).

Q: If a carrier is non-compliant is it considered recalled? Can it still be safe?

A: Products should be recalled in the event of serious potential safety hazards but products are also frequently recalled as a precautionary measure or for quality reasons that have nothing to do with safety. A product that is say, improperly tagged would technically be considered non-compliant, but this would not necessarily indicate the need for a product recall. One thing to keep in mind is that these regulations apply to the US only. Other countries have different regulations and safety standards in place.

So many acronyms, I’m still confused about who does what!

This video does a great job of explaining all the ins and outs and the history of the industry:

https://www.youtube.com/watch?v=jBWRos_IVlI&feature=iv&src_vid=uPq7UPjVJfg&annotation_id=annotation_1581869141#t=3s

Do you have a carrier safety or compliance question? Contact the BCIA atdirector@babycarrierindustryalliance.org and we’ll do our best to add it to our Compliance FAQ.

mhc slings

myheartcreative Ring Slings

 

Factory production

 

wrap stack

Cassiope Woven wraps

 

 

 

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