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Monday September 09, 2019

Recall Registration Updates to Include Year Phase-in for Contoured Pads

Commissioners voted 5-0 September 4 to publish a final rule that will revise CPSC's requirements for recall registration cards for nursery items. Although the effective date will be 30 days after the rule appears in the Federal Register for most products, there will be 12-months compliance leeway for contoured changing pads.


The updates address definitions, including for the broad class subject to the rules: durable infant or toddler products. The full statutory definition now will be in the rule, rather than just the current list of 18 categories. It will state that such items are "intended for use, or that may be reasonably expected to be used, by children under the age of 5 years."


That section also will say the classes are further defined in other mandatory standards. As for the list of products, there will be the following updates:

  • Infant carriers will get the subsets sling carriers, soft infant and toddler carriers, handheld infant carriers, and frame child carriers.

  • Bassinets will get the subset bedside sleepers.

  • Changing tables will be called baby changing products.

The year phase-in for contoured changing pads had been opposed by consumer groups, who argued that many makers of such items already make product subject to the registration rules so have needed systems in place (PSL, 1/14/19).


In the briefing package (, agency staffers explained that 13 of 25 identified pad makers, in fact, do not make products already subject to the card rule. In the proposal (PSL, 10/15/18), staffers wrote that the year phase-in was consistent with the time given in 2009 when CPSC originally put the registration-card requirements in place.


The cards were established by the CPSIA in 2008. Their purpose is to aid companies' abilities to contact buyers of recalled products. To improve returns, the collected information cannot be used for marketing.