What are the Amazon ASTM F1004 and 16 CFR 1239 Tests?

On July 6, 2020, the U.S. Consumer Product Safety Commission (CPSC) issued the final regulation 16 CFR 1239, establishing safety standards for infant gates and enclosures. This regulation incorporates and revises the latest version of ASTM F1004-19, Standard Consumer Safety Specification for Expansion Gates and Expandable Enclosures, and came into effect on July 6, 2021. To export child safety gates and enclosures to the U.S. market, compliance with the American Society for Testing and Materials (ASTM) F1004 standard and the Consumer Product Certificate (CPC) under 16 CFR 1239 is required.

According to Amazon's requirements, all child safety gates and enclosures must be tested and comply with the following specific regulations or standards:

All of the following:

1. Consumer Product Safety Improvement Act (CPSIA) (Lead, Phthalates);

2. Consumer Product Safety Act Section 14(a)(5) (Tracking Labels);

3. U.S. Code of Federal Regulations, Title 16, Part 1130 (Consumer Registration Requirements for Durable Infant or Toddler Products).

Any one of the following:

1. ASTM F1004-22 (Standard Consumer Safety Specification for Expansion Gates and Expandable Enclosures);

2. ASTM F1004-21 (Standard Consumer Safety Specification for Expansion Gates and Expandable Enclosures);

3. 16 CFR 1239 (Safety Standard for Gates and Enclosures).

ASTM F1004 Requirements for Child Safety Gates and Enclosures:

1. Fully Enclosed Openings: This requirement aims to address incidents where children get trapped when squeezing between soft or flexible gates and enclosure components, or between the gate and the enclosed passageway (such as door frames or walls).

2. Side Height: This requirement prevents children from leaning over and falling over the top of the gate.

3. Vertical Strength: This ensures that child safety gates and enclosures can contain children even if they hang on the gate or try to climb over it.

4. Bottom Clearance: This requirement addresses incidents where children’s heads get trapped under the gate after first squeezing their feet through the gap between the gate and the floor.

5. Top Configuration: This aims to prevent head/neck entrapment incidents reported in older accordion-style gates with "V"-shaped openings.

6. Latch/Locking and Hinge Mechanisms: This pre-treatment test addresses accidents related to latch, hinge, and hardware failures.

7. Automatic Closing System: This ensures that the gate closes and locks completely as expected and advertised, reducing the risk of children unintentionally entering hazardous areas through an unlatched gate.

8. Push-Out Force Strength: This prevents children from moving the gate and entering restricted areas meant to be blocked off.

9. Locking Mechanism: This requirement ensures that children inside the gate cannot operate the locking mechanism.

10. Toys: Toy attachments should not be affixed to or sold with child safety gates. Any toy attachments that are removable or sold with the enclosure must meet applicable ASTM F963 Consumer Safety Specification for Toy Safety standards.

11. Slat Strength: This ensures that child safety gates and enclosures maintain structural integrity when children push or pull on the slats.

12. Label Durability Test: Paper and non-paper labels (excluding those affixed through seams) should not peel off without the use of tools or solvents.

13. Wall Cup Warning Labels: Pressure-mounted gates that include wall cups must have a separate warning label on the top rail, instructing proper installation using wall cups to pass the 30-pound push-out force test.

14. Visual Side-Pressure Indicators: Pressure-mounted gates that do not use wall cups to meet the 30-pound push-out force test must have visual side-pressure indicators to provide consumers with feedback on whether the gate is properly installed.

Warnings, Labels, and Instructions: These regulations specify the marking, labeling, and instructional documentation required for each gate or enclosure. Retail packaging must also display warnings unless the full warning is visible on the child safety gate or enclosure at the point of purchase.

16 CFR 1239 Requirements for Child Safety Gates and Enclosures:

According to the Consumer Product Safety Improvement Act (CPSIA), child safety gates and enclosures must meet requirements for surface coatings, lead content, testing and certification, registration cards, and tracking labels.

1. Surface Coating Limits: Gates and enclosures must not be coated with paint containing more than 90 ppm (0.009%) lead.

2. Lead Content Limits: In any accessible part of the gate or enclosure, total lead content must not exceed 100 ppm (0.01%).

3. Testing and Certification: Like all products primarily designed for children aged 12 or younger, gates and enclosures must be tested by a CPSC-accredited third-party laboratory to comply with safety standards, including lead paint and lead content limits. Based on these tests, the domestic manufacturer (or importer) must issue a Children’s Product Certificate (CPC) detailing each applicable regulation and certifying compliance.

4. Product and Packaging Labeling Requirements: Durable infant or toddler products like gates and enclosures must be permanently marked with specific labeling information, including tracking labels, on both the product and its packaging.

5. Product Registration Card Requirements: Additionally, durable infant or toddler products must include extra product markings and a product registration card attached to the product. The following chart summarizes the specific labeling and registration requirements that durable infant and toddler products must meet.