The CPSC Substantial Product Hazards List contains consumer products that include features that might present a risk to the general public. As an example, children’s upper outerwear with drawstrings might present a risk of strangulation for kids.
As such, importers and manufacturers should ensure that their products, if mentioned on the list, adhere to the requirements of appropriate standards.
In this guide, we explain what substantial product hazards are. We also list them, including their definition, relevant standards, and more.
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What are Substantial Product Hazards?
16 CFR Part 1120 defines a “substantial product hazard” as a product defect that is substantially risky to the public because of reasons such as:
- The product’s defect pattern
- The number of defective products on sale
- How severe the risk is
Product scope
Specifically, this part covers products with characteristics that, when either present or absent, might substantially injure the public. The CPSC deems the following products as substantial product hazards if they fail to comply with the requirements of relevant standards:
- Hand-supported hair dryers
- Children’s upper outerwear sizes 2T to 16
- Seasonal and decorative lighting products (e.g. light sculptures)
- Extension cords
- Stock window coverings (e.g. a shade)
- Custom window coverings (e.g. a custom blind)
Standards
For each one of the above product or product categories, the CPSC incorporates by reference one or more UL, ASTM, or ANSI standards under 16 CFR Part 1120. This means that compliance with the requirements of the standards is made mandatory.
Note that, in some cases, the CPSC requires compliance with only some parts of the standards.
Hand-supported hair dryers
The CPSC deems hand-supported hair dryers to be substantial product hazards if they fail to provide integral immersion protection as required by either section 5 of UL 859, or section 6 of UL 1727 standards.
Definition
This part defines a “hand-supported hair dryer” as a hand-held electrical appliance that creates an airflow over or through a self-contained heating element, with the aim of drying hair.
Standards
16 CFR Part 1120 incorporates by reference the following two standards:
a. UL 859 – Standard for Safety for Household Electric Personal Grooming Appliances
b. UL 1727 – Standard for Safety for Commercial Electric Personal Grooming Appliances
Children’s upper outerwear in sizes 2T to 16
The CPSC deems children’s upper outerwear featuring one or more drawstrings to be substantial product hazards if the garments fall under the scope but do not comply with the requirements of ASTM F 1816-97 standard.
Definition
16 CFR Part 1120 doesn’t provide a definition of children’s upper outerwear. However, it states that products in sizes ranging from 2T to 16 that come with one or more drawstrings, either at the hood or at the bottom, and that fall under the scope of ASTM F 1816-97, are covered. You can find more information in this FAQ.
Additionally, “drawstring” is defined as a cord, tape, or ribbon of any material that cannot be retracted and is meant to pull parts of upper outerwear together to provide closure.
Size determination
This part provides guidance on how one can determine the size of an upper outwear product. This is important as only products in certain size ranges must comply with the requirements of ASTM F 1816-97. Specifically, garments that are in:
a. Size Extra-Small (XS) are equivalent to sizes smaller than size 12.
b. Size Small (S) are equivalent to sizes smaller than size 12.
c. Size Medium (M) are equivalent to sizes smaller than size 12.
d. Size Large (L) are equivalent to a size 12.
e. Size Extra-Large (XL) are equivalent to a size 16.
Sometimes garment labels have a range of sizes, only some of which might be within the range of 2T to 16. For example, a product might have a range of sizes from 14 to 18.
As a part of the range (14 to 16) is under the scope of the relevant ASTM standard, the product should comply with its requirements.
Note that the CPSC may use any appropriate evidence to demonstrate that a product has a size equivalent to sizes 2T to 16.
Standards
The following standard is incorporated by reference in this part:
ASTM F 1816-97 – Standard Safety Specification for Drawstrings on Children’s Upper Outerwear
Seasonal and decorative lighting products
The CPSC deems seasonal and decorative lighting products to be substantial product hazards if they do not comply with the requirements listed in sections 6, 7, 15, 71, 79, and SB15 of UL 588. Those requirements pertain to minimum wire size, sufficient strain relief, and overcurrent protection.
Definition
16 CFR Part 1120 defines seasonal and decorative lighting products to include accessories and lighting products that are portable, can be connected by a plug, and are for short-term use. Additionally, these products must have a nominal input voltage rating of 120 volts, in order to fall under the scope of this part.
The CPSC provides examples of covered products, such as the following:
- Lighted decorative outfits (e.g. starts)
- Candles without shades
- Light sculptures
- Animated figures
This part does not cover the following lighting products:
- Battery-operated products
- Solar-powered products
- Transformer-operated products
- Flexible lighting products
- Portable electric lamps
Standards
16 CFR Part 1120 incorporates by reference the following standard:
UL 588 – Standard for Safety for Seasonal and Holiday Decorative Products
Extension cords
The CPSC deems extension cords to be substantial product hazards if they do not comply with the requirements of several sections of UL 817, which are listed in 16 CFR Part 1120.3(d). Those requirements pertain to:
- Minimum wire size
- Sufficient strain relief
- Proper polarization
- Proper continuity
- Outlet covers
- Jacketed cords
Definition
This part defines extension cords as flexible cords that are factory-assembled, have an attachment plug (or a current tap) as a line fitting, and have a cord connector as a load fitting.
This rule covers extension cords that are:
a. Equipped with National Electrical Manufacturer Association (“NEMA”) 1–15, 5–15, and 5–20 fittings, and
b. Meant for use either indoors only, or both indoors and outdoors.
It does not cover the following cords that are supplied with outdoor tools and yard-use equipment:
- Detachable power supply cords
- Appliance cords
- Power strips and taps
- Adaptor cords
Standards
16 CFR Part 1120 incorporates by reference the following standard:
UL 817 – Standard for Cord Sets and Power-Supply Cords
Stock window coverings
The CPSC deems stock window coverings to be substantial product hazards if they do not comply with the requirements in sections 4.3.1, 4.5, 6.3, 6.7, and Appendices C and D of the ANSI/WCMA A100.1-2018 standard. Those requirements pertain to the following:
- Operating cords
- Inner cords
- On-product manufacturer labels
Definition
According to this part, stock window coverings are entirely, or in most part, manufactured before distribution for sale, and are specific SKUs. The definition still applies even if the manufacturer, distributor, or seller modifies the product, for instance tying cords to secure the bottom rail.
Standards
16 CFR Part 1120 incorporates by reference the following standard:
ANSI/WCMA A100.1-2018 – American National Standard For Safety Of Corded Window Covering Products
Custom window coverings
The CPSC deems custom window coverings to be substantial product hazards if they do not comply with one or more requirements in sections 4.5, 6.3, 6.7, and Appendices C and D of the ANSI/WCMA A100.1-2018 standard. The requirements pertain to the inner cord and on-product manufacturer labels.
Definition
Per 16 CFR 1120, Custom window covering (e.g. custom blinds, or shades), is defined as a window covering that fails to meet the definition of “stock window covering”.
Standards
This part incorporates by reference the following standard:
ANSI/WCMA A100.1-2018 – American National Standard For Safety Of Corded Window Covering Products
Lab testing
Although 16 CFR Part 1120 does not explicitly mention lab testing, in general, you need to have your products lab tested if you want to prove that they comply with the requirements of the standards incorporated in this part.
For instance, to prove that your extension cords comply with UL 817’s requirements, you need to have them tested against the requirements of the standard.
When your product passes lab testing, you receive a test report that proves your product’s compliance with the relevant standard.
Lab testing companies
Here, we list a few test companies that claim to test products to one or more of the standards that are incorporated by reference under 16 CFR Part 1120:
- SGS
- Eurofins
- QIMA
- Bureau Veritas
- F2 Labs
- UL Solutions
