CPSC Issued a New FAQ Regarding Drawstrings in Children’s Upper Outerwear


CPSC Issued a New FAQ Regarding Drawstrings in Children’s Upper Outerwear

On July 19, the Consumer Product Safety Commission (CPSC) posted a new FAQ on their website which provides some clarifications to the current drawstring requirements of ASTM F1816-97 and 16 CFR 1120.


Background
Last year, on July 19, 2011, the CPSC published a final rule, stating that children’s upper outerwear garments which have neck or hood drawstrings (in sizes 2T to 12), and those which have waist or bottom drawstrings (in sizes 2T to 16) that do not meet the criteria of the previously voluntary standard, ASTM F1816-97, Standard Safety Specifications for Drawstrings on Children’s Upper Outerwear, present a substantial product hazard.  The new rule, 16 CFR 1120, became effective on August 18, 2011.

16 CFR 1120 included some points in addition to that included in ASTM F-1816-97, such as:
  • The definition of a “drawstring” is “a non-retractable cord, ribbon, or tape of any material to pull together parts of outerwear to provide for closure”. This definition considers ties to be drawstrings, as well as traditional tunneled drawstrings.
  • Size equivalents for garments that are sized under S, M, L sizing system are as follows: Girls’ and Boys’ sizes Large (L) are equivalent to size 12. Girls’ and Boys’ sizes Extra-large (XL) are equivalent to size 16.
The apparel industry raised questions with the CPSC following finalization of the rule.  The FAQ clarified several other points as well.  The most noteworthy are as follows:
  • Definition of upper outerwear:  In addition to “clothing, such as jackets and sweatshirts, generally intended to be worn on the exterior of other garments”, the CPSC clarified that “lightweight outerwear that is appropriated for use in warmer climates” is also included. 
  • Underwear, inner layers, pants, shorts and skirts are excluded from the definition.
  • The CPSC reiterated that ties are included in their definition of drawstrings.
  • It was clarified that belts are not included in the scope of the drawstring rule.
  • Definitions of "non-retractable" and "fully retractable" were addressed.
  • The CPSC listed additional requirements for children’s upper outerwear which are required by the Consumer Product Safety Improvement Act of 2008, as follows:
    • Lead in surface coatings
    • Total lead content
    • Testing and Certification
    • Tracking Labels
The CPSC also provided the legal rationale behind creating a list of “substantial product hazards”, as permitted under section 15(j) of the CPSA.

Following is a link to the CPSC’s FAQ:  http://www.cpsc.gov/businfo/drawstringsfaq.html



Bureau Veritas Consumer Products Services, Inc. ("BVCPS") provides the information in this client bulletin as a resource of general information. It does not replace any applicable legal or regulatory requirements and is provided "as is." BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.


Copyright © 2012 Bureau Veritas Consumer Products Services, Inc. All Rights Reserved.

Contact us
Bureau Veritas
Send an e-mail
Related Links