Which Safety Standards Apply to Infant Bath Tubs?
Infant bath tubs, bath seats, bath supports, and bath slings are children's products with their own product-specific safety standard. These products are used with water, which creates drowning hazards that the standard specifically addresses. Your CPC must list the bath tub standard along with chemical safety requirements — and because these products are used by very young children, phthalate compliance is especially important.
Bath Tub Safety Standards
Standard Consumer Safety Specification for Infant Bath Tubs
This standard covers infant bath tubs, bath seats, bath supports, and similar products used to bathe infants. It addresses stability (resistance to tipping when wet), structural integrity, suction cup retention (for bath seats that attach to tubs), drainage requirements, and entrapment hazards. The standard also sets requirements for water temperature warning labels and drowning hazard warnings.
Bath seats that attach to adult bathtubs have additional requirements for the attachment mechanism — they must resist detachment during use and must not create a false sense of security that would lead a caregiver to leave the child unattended.
Safety Standard for Infant Bath Tubs
This is the mandatory federal regulation that incorporates ASTM F2670 by reference. Your CPC should reference 16 CFR 1234 as the federal standard. Test reports should demonstrate compliance with the current version of ASTM F2670.
Chemical Safety Standards
Lead Content Limits (100 ppm)
Total lead in accessible materials must not exceed 100 ppm. For infant bath tubs, this applies to the plastic tub body, any metal drain hardware, painted or printed surfaces, rubberized non-slip surfaces, and any thermometer or temperature indicator components built into the tub.
Ban on Lead-Containing Paint (90 ppm)
Any painted or printed surface on the bath tub must comply with the 90 ppm lead paint limit. This includes printed designs, temperature-change color indicators, and any surface coating on the tub or accessories.
Phthalate Content Limits
Phthalate limits are particularly important for infant bath tubs because the entire product is typically made from soft or semi-rigid plastic, and infants frequently mouth the edges of the tub during bathing. Soft PVC tubs, rubberized grip surfaces, soft plastic bath slings, and inflatable bath tubs all need phthalate testing. Even seemingly rigid tubs may contain plasticizers that require evaluation.
Common Mistakes with Infant Bath Tub CPCs
- Overlooking phthalate testing. Bath tubs are almost entirely plastic and are used by very young infants who mouth everything. Phthalate testing is essential for the tub body, not just accessories.
- Not testing bath seats separately. If you sell a bath seat that attaches to an adult tub, it has additional suction cup and attachment requirements under ASTM F2670. A freestanding tub test does not cover a bath seat.
- Missing required drowning warnings. The standard requires specific drowning hazard warnings. Omitting these warnings is a compliance failure even if the tub passes all physical tests.
- Ignoring the drain requirement. Some versions of the standard require that bath tubs have drainage provisions. Check your test lab's findings against the current version.
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