Baby Stroller Regulations in the United States: A Complete Guide

Baby strollers and walkers sold in the United States must comply with safety standards and substance restrictions. In addition, compliance with certification, labeling, and testing requirements is also mandatory.

In this guide, we take a closer look at the CPSIA, ASTM F833, California Proposition 65, and other compliance requirements relevant to baby strollers in the US.

Consumer Product Safety Improvement Act (CPSIA)

The Consumer Product Safety Improvement Act (CPSIA) sets safety requirements for products intended for children aged 12 and under, including strollers.

The CPSC defines “strollers” as wheeled vehicles that are used to transport one or more babies or children. The difference with a carriage is that while children lie down in carriages, they sit up in strollers (usually in a reclined position).

The CPSC’s business guidance page for carriages and strollers lists several product requirements. For instance, strollers should:

• Have latching and locking mechanisms to prevent accidental collapse
• Be stable to avoid tip-overs
• Not have small parts
• Be labeled to address entrapments and falls

Additionally, you should comply with:

• Substance restrictions
• Relevant standards
• Testing and certification requirements
• Labeling requirements

Finally, note that the CPSC lists strollers as durable infant products, which means that strollers are subject to additional requirements.

Substance restrictions

In general, your stroller should comply with the following substance restrictions:

a. Surface coating limit – the paint in the product should not contain more than 90 ppm of lead

b. Lead content limit – the products should not contain a total lead content exceeding 100 ppm in accessible components

c. Phthalate content limit – parts that are designed to help the baby sleep or facilitate eating should not contain more than 0.1% of the following phthalates

• DEHP
• DBP
• BBP
• DINP
• DIBP
• DPENP
• DHEXP
• DCHP

Relevant standards may also set additional substance restrictions.

ASTM F833 – Standard Consumer Safety Performance Specification for Carriages and Strollers

ASTM F833 is incorporated by reference in 16 CFR Part 1227 – Safety Standard for Carriages and Strollers. it sets safety performance requirements, labeling requirements, and test methods for carriages and strollers to mitigate potential hazards to children.

The standard does not apply to the following children’s products:

• Tricycles
• Bicycles
• Self-propelled wheeled products

Carriages and strollers should not bear an indication of compliance with this standard’s requirements unless they comply with all requirements in the standard.

Documentation

The CPSIA requires you to provide both a Children’s Product Certificate and a product registration form.

Title	Description
Children’s Product Certificate	Importers or manufacturers of children’s products, such as carriages and strollers, are required to issue a Children’s Product Certificate to certify that their products comply with the CPSIA requirements.
Product Registration Form	The CPSIA requires you to provide a product registration form (or card) with your durable infant or toddler products, such as carriages and strollers. The CPSC registration forms business guidance page provides an example of such a card.

Labeling

You should permanently mark the stroller, and its packaging, with specific labeling information.

Title	Description
Tracking label	Your label should contain the following information: Manufacturer name Date and place of manufacturing Product information (e.g. batch number)
Additional requirements for durable infant products	You should also provide the following information on your label: Manufacturer address and phone number Model number

16 CFR Part 300, Part 301 – Wool and Fur Acts and Rules

Products containing wool or fur parts should comply with the requirements set by 16 CFR Parts 300 and 301. Specifically, they should comply with the following labeling requirements:

a. Fur name (e.g. “Alpaca”) – if applicable

b. Fiber content – Wool products should bear the fiber content on the label (e.g. 100% wool)

c. Traceability – manufacturers are mandated to provide either their registered identification number or their business name

d. Country of origin (e.g. Made in Vietnam)

e. Claims – manufacturers are required to not mislead or deceive consumers as to the nature of the product

Note that, according to the FTC guidance page “Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts”, strollers are exempt from the requirements set by 16 CFR Part 303, which concern textile products.

California Proposition 65

California Proposition 65 sets restrictions on substances used in consumer products sold in the United States, such as baby strollers.

Components of baby strollers may contain restricted substances such as the following:

a. Lead – may be found in the paint of metal components of the stroller frame. It is limited to a No Significant Risk Level (NRSL) of 15 µg/day and a Maximum Allowable Dose Level (MADL) of 0.5 ug/day.

b. DEHP – may be found in plasticized parts (e.g. buckles). It is limited to a MADL of 58 µg/day for infant boys (aged 29 days to 24 months) and 20 µg/day for neonatal infant boys (aged 0 to 28 days).

c. BBP – may be found in plastic components (e.g. trays). It is restricted to a MADL of 1200 µg/day.

d. DBP – may be found in plasticized components (e.g. handles). It is limited to a MADL of 8.7 µg/day.

e. DINP – may be found in plastic parts. It is restricted to an NRSL of 146 µg/day.

California Proposition 65 also requires you to provide warnings on the product label that indicate the presence of and exposure to listed carcinogenic and reprotoxic substances, such as the ones listed above. This warning labeling is mandatory unless you are sure that your product does not contain restricted substances above the limit (for example because you pass lab testing).

19 CFR Part 134 – Country of Origin Marking

Baby strollers, like most consumer products, are subject to the country of origin marking requirements when they are imported into, and sold in, the United States.

For instance, if the stroller is made in Vietnam, then it should bear a marking that states “Made in Vietnam”. As another example, if the components of the stroller are made in Vietnam but assembled in Mexico, then the label or marking could read: “Assembled in Mexico from components of Vietnam”.

Lab testing

You should get your baby strollers tested to ensure that they do not pose mechanical, physical, or chemical hazards (e.g. entrapment, strangulation, or lead exposure). Some regulations mandate that you have your product tested (e.g. CPSIA). Other regulations may not mention “testing”. Regardless, you should still have your product tested as a practical necessity in the interest of product safety.

If your product passes lab tests, you receive a test report containing evidence that your product is in compliance with the relevant regulatory requirements and standards.

Regulation	Lab testing
CPSIA	You should have your baby stroller tested by a third-party, CPSC-accepted test lab. For example, the product should be tested for: Impact testing to ensure product durability Chemical testing Other relevant tests to ensure, for instance, that the product does not have small parts or pose entrapment, strangulation, or fall hazards
California Proposition 65	You should test your baby stroller product to ensure it does not contain any restricted substances (e.g. the frame or plastic components) that are present on the California Proposition 65 List. Here are some examples of these substances: Lead Phthalates (e.g. DEHP, DBP, BBP, DINP)

Baby stroller testing companies

Here are some CPSC-accepted labs that can test baby strollers according to the requirements set by 16 CFR Part 1227 – Safety Standard for Carriages and Strollers:

• Bureau Veritas
• Intertek
• SGS
• TÜV Rheinland
• QIMA