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FAQ: Baby carrier compliance for consumers

This baby carrier compliance FAQ was first published in April of 2019. It was last updated in March of 2022.

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 this FAQ.

Questions and answers about baby carrier product compliance

Q: Why is compliance important?

A: Primarily because it protects consumers. Many countries have laws that regulate products. There are lead and other chemical limits to consider. Product flammability. Some standards require testing for strength and durability. Public health organizations want to ensure children’s product don’t 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, to the families their products serve, and to ensuring their products are safe for babies and parents.

A product that has not met the legal requirements for compliance may or may not be safe. However, it may be wise to ask yourself, 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: Regulations governing children’s products vary from country to country. 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. In Europe, there are standards for both slings and carriers. Canada has specific regulations that are not included in the US regulations. China has its own set of rules. The list goes on.

Embedded in these laws and regulations are rules about things such as record-keeping and testing plans that you won’t see as a consumer. However, there are a few things you can look for to see whether a product is compliant with local law and best practices. To break it down simply, a consumer is looking for three things:

  • Proper labeling
  • Product registration (not always required by law, but required in the US and good to have)
  • 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: A product registration card is a postcard included with the product that you fill out and return. This card gives the company your contact information and details about which product you’ve purchased so they can contact you in the unlikely event of a product recall.

In the US, the postcard must meet specific standards. For instance, it must be 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.

When you register your products, manufacturers will be able to easily access your data and connect it with a particular product. 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,which can leave you uninformed if there is ever a recall for the product.

Q: How should a baby carrier be labeled?

A: Baby carriers require a few different labels, and this varies from country to country. Here is the information required in the US.

Permanent tracking and product label

In the US, baby carrier compliance requires that is a product carries a label (or labels) including information about:

  • manufacturer details (address or phone number, website)
  • where a product was made
  • a product number or model name
  • date of manufacture

This information should be on the product’s outer packaging as well.

These permanent tracking labels are one of the most useful regulations in the US. In the event of a recall or incident, it allows both you and the product manufacturer to pinpoint which products might be affected. It also tells you, as the customer, when your product was made, which can be useful when 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, it was likely manufactured before that date.

Care labels

Care labels are a requirement under the US Textile Act. Your baby carrier should be tagged with labels that identify fiber content, product origin, and care instructions. This ensures you know what your product is made of, where it came from, and how to wash it. This is the same act that governs clothing labels in the US.

Product warning label

In the US, all baby carriers are required to meet international standards put forth by ASTM and adopted by the CPSC. These standards govern things like:

  • required mechanical/physical testing to the weight specified on the carrier label
  • choking and strangulation hazards
  • product warning labels
  • use and care instructions
Example of a compliant ring sling with warning label, attached product registration card and batch/care/company label. This sling is from Sewfunky circa 2019.

Q. Can customers remove product labels?

A. A customer can do absolutely whatever they want with their own product once it is purchased, including removing labels if they choose. A few things to consider before doing so:

  • these labels are meant to help protect new caregivers/consumers. If you expect to pass the carrier to someone else or sell it in the future, it would be best to leave labels on.
  • in the US, warning labels must be sewn down along all four sides of the label.
  • while customers can do as they wish with their own property, please do not ask your manufacturers to circumvent this law by making a label easier to remove. Manufacturers don’t want to choose between breaking the law and disappointing a customer.

Q: Can I still have a wrap or my own fabric converted into a ring sling/ meh dai/ carrier of my choice? What about custom woven wraps?

A:In the US, Canada, Australia, New Zealand, the EU, and many other places, custom baby carriers generally cannot meet regulations and standards.

The exception is when the baby carrier manufacturer or weaver makes only products they have tested to comply with the standards. Examples include products that meet all labeling and packaging requirement and may also include:

  • handwoven wraps made from fibers and techniques tested to the relevant standard
  • baby carriers tested to the relevant standard that use custom fabric only as a decorative accent that does not add to or change the product functionality
  • wrap conversion slings done by a company who test and certifies their design with particular wrap brands and styles to ensure their conversions meet local regulations

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

A: There are no official regulations specifically governing baby carrier accessories.

Although general children’s product requirements apply, do not assume that a baby carrier positioning insert, suck pads, or other accessorieshave been tested with your carrier. Always exercise caution with aftermarket products.

For more information, see our article on accessories here: Customized Carriers, Accessories & Embellishments – Baby Carrier Industry Alliance

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 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 that are not intended to be sold or given away are not subject to regulations. They 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: 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 come with that. The CPSC and other government organizations really don’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, just as 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. Altering the function of a carrier (weight bearing portions, buckles, webbing etc.) is not advised.

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 cannot 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 a product has been recalled before selling or purchasing. 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.

Q: Can/ should I report noncompliant baby carriers? How do I do that? What if I think a baby carrier is unsafe?

A: In the US, when a manufacturer becomes aware their product doesn’t comply with a mandatory standard, or they become aware of a substantial hazard, they are required to report that to the CPSC. However, the regulations themselves are complex and confusing. If you believe a product is not in compliance with a mandatory standard or poses a substantial hazard, you should contact the manufacturer first. You may learn that the product is actually in compliance with regulations.

Since the agency’s inception, consumers have also been invited to call the CPSC’s hotline if they are concerned that a product creates a substantial hazard. More recently, consumers can report concerns 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 rules or regulations determining how a carrier must be constructed. When a carrier is tested to an international standard (like ASTM F2236 or F2907 or to the European standards EN13209 or TR16512), it’s subjected to 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.

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: All baby carriers imported into the US must be compliant with US regulations. Some overseas manufacturers work with a US-based retailer or distributor in order to share compliance responsibilities. Non-compliant products 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 are generally recalled due to serious potential safety hazards. Occasionally, products may be recalled as a precautionary measure or for quality reasons that have nothing to do with safety. A product would generally not be recalled in the US due to a labeling issue or similar compliance issue. Other countries have different regulations and safety standards in place.

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

A. 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 at director@babycarrierindustryalliance.org and we’ll do our best to add it to this baby carrier compliance FAQ.

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