Navigating the regulations around baby carrier compliance labeling for slings, wraps, and other babywearing products can be complicated. They also change from time to time as the baby carrier compliance laws and standards are updated.

2022 Baby Carrier Compliance Labeling Rules

In August of 2022, the US Consumer Product Safety Commission updated the existing regulations for baby sling and baby wrap carriers. When they adopted ASTM F2907-22, the baby carrier compliance labeling rules changed.

If you’d like to learn more about the process of adopting the updated baby carrier standard, you can read our press release on the subject here: “What’s New in the F2907-22 Sling Standard?”

Key Changes to the Baby Sling Standard Labeling Rules

To learn more about the updates to the F2907-22 sling standard, watch this video. It will show you everything you need to read in order to understand the baby carrier compliance labeling rules.

Video Transcript for Baby Carrier Compliance Labeling

Hi there. This is Kristi Hayes-Devlin. I am the executive director of the Baby Carrier Industry Alliance and I would like to talk to you about the updates to the United States sling standard that have been approved in August 2022 by the US Consumer Product Safety Commission.

There are a few minor changes that we’re not really going to cover here. They are tiny verbiage changes and some changes to the packaging requirements, but there’s nothing you need to add or really be aware of. If you’d like to learn more about that and you’re a member, we cover it on our blog.

However, what do you need to know in order to implement the changes and to continue to be compliant with the standard?

The key changes affect the product warning label. First of all, there’s a new label format required. Your warning text — except for the word “warning” — must be left justified and use bullet points.

If you’ve been purchasing your labels from the BCIA or using our template, you’ll see that we’ve been using that format. However, I know that some of our members have been using different kinds of formats, and that’s OK, but the labels as of November 19 need to follow this format where the warning text is left justified and uses bullet points.

“Left justified” means that you can’t do the “justified” — the justified fonts or rather formatting where the paragraph alignment is straight on both the left and the right because that spreads out the text in a way that’s less intuitive and easy to read and the purpose of this formatting is to ensure that the warning labels are very easy for the consumer to absorb and consumer.

There’s some new verbiage on these labels. In the first paragraph of the warning text you’re going to add the phrase “these warnings.” That’s all covered in section 8 of ASTM F2907-22 which I’ll tell you how to purchase. That’s the updated version of the standard; it’s the 2022 version.Previously we were using the F2907-19 version.

The box behind the word warning now has to be in safety orange. This is a big change. safety orange is Pantone color 151C. So instead of just having a contrasting box, for example a white box with black text or a black box with white text, you now have to have the word warning a orange box with black text in addition to your safety symbol.

So, your to-do list for implementing these changes and your timeline.

First of all, on or before November 19, you’ll need to have your labels ready. So you’ll need to either redesign your labels and have them printed. OR you can purchase your label template from the BCIA that is in the process of being tested by AM Testing to ensure it’s compliant and that we are giving you something that is in line with the new regulation.OR you can purchase printed labels from the BCIA in larger or smaller quantities, and watch your email for information on how you can preorder those labels so that you can get them as soon as they arrive.

Again,as soon as we get our thumbs up and green light from AM testing, which should be very shortly, in the next day or three, we’re gonna go ahead and have those printed, and we should have them ready to deliver to you I hope by November 1 of 2022.

You’ll have to use the new labels. All products made on or after November 19 have to use the new label format. The new warning labels. So UNTIL November 19 you can continue to use existing labels, use up your existing inventory, your old stock, but after November 19, you’re going to want to switch to the existing — um — the new format with the orange background and the left justified and the new verbiage.

And again this is for F2907-22 carriers — sling type carriers. If your carrier is covered by F2236-16 for soft carriers then these changes do not yet apply to you, although they are coming in the future.

You need to secure your labels on all four sides and make sure they’re really secure. This includes heat transfer labels which obviously you’re not going to sew, but they need to be attached to your carrier on all four sides.

This is a question I’m getting a lot of.Product testing. Do you need to retest because of the change to the standard?

No. Not exactly. On November 19, is your responsibility as a company to ensure that your labels are compliant.

If you purchase your labels from us will have a compliance certificate that will ensure that you have for your records a certificate of compliance that shows you know you are purchasing a compliant label and that we are guaranteeing that we have had those labels tested and that they meet the new standard.

That is sufficient for your own needs to ensure that the standards are met. You don’t need to re- test your product on November 19. NOT until your next scheduled test date.So if you are due for annual testing in June, for example, you can still test your product in June. And when you test your product they will be using the new F2907-22 standard, but by then you’ll have already been compliant on all products that you’ve made on or after November 19. Let’s say that you are testing your products in October 2022 or the beginning of November. Prior to the when the standard goes into effect.

When they do that test, they can do the test utilizing the existing standard which is F2907-19, and if you have the existing label format without the orange bar and the existing verbiage, then your carrier will ass testing.

However, even if you test at the beginning of November utilizing the existing labels, you still have to change your labels on November 19 regardless of when you have completed the product testing. If you have questions about this transition or need support please feel free to set up a phone call or drop me an email and we can talk about it.

How do you get the updated standard? This has been a bit tricky because it was not available online immediately. But if you are an ASTM member — What is the ASTM? ASTM is completely separate from the BCIA and is completely separate from the US government CPSC. ASTM is a nonprofit international standards writing organization and the United States Consumer Product Safety Commission, or CPSC, usually or often adopts ASTM standard when they need a mandatory standard. They have in this case as well.

There are two ways you can purchase the standards. One is to just go on their website and purchase it without become a member. And the other is to become or be an ASTM member, which costs approximately $75.

ASTM members can vote on certain things, participate in subcommitteee and task groups and then all of these things, and when you are an ASTM member, you can accessthe entire category of standards in the category for which you are a member. So for example, I am an ASTM member and my categories is F15, and that covers children’s consumser products.

So I have access as an ASTM member to the F2907-22 standard but also to all the previous iterations of that standard.
I can go back and compare it to what was coming before the F2907-21, -19, and so forth. I can also access the F2236 standard or the swing standard etc. So membership is not significantly more expensive than the cost of the standard and provides you access to the standards. You do need to logon and vote on ballots and keep your membership active, but it’s a very low investment membership.

If you are an ASTM member, here’s where you’re going to get your standard because it can be a little tricky to find it in your membership portal. So first, you’re going to go to ASTM.org, and if you look at this little arrow on the top right click the sign in button.

Next you are going to view the drop down in the top right corner and when you drop down you will see compass as an option and when you click on compass that will take you (follow the orange arrow) to this screen. There’ll be 4 tabs on top. So recently accessed, something else, favorites, and subscriptions.

When you click on the subscriptions tab, you’ll see the square box — look at the number 2 — that says ASTM. And that will bring you to a new window, andn within that window is a search box up top “my subscription.” And in that window in the search box type in the name of the standard you are trying to search; it’ll drop down; click on that and then you’ll have the standard pulled up and ready to download and you’ll be ready to go.

If you wanted to look for a different standard, obviously type in a different standard. There are keywords you can use and so forth.

If you are no and ASTM member, here’s what you’re going to do. Go to ASTM.org. There’ll be a search bar at the top right. You’re going to search for F2907-22.You’ll click on the link to the standard. It’ll give you a purchase option. You will purchase it for $54.

And again, you can become an ASTM member for $75/year and get access to all the F15 standards including the revisions as long as your membership remains active.

Here’s the thing. F2907-22 two references additional standards when it describes how to make these warning labels. And with all of these organizations, their standards are copyrighted, which means you have to purchase them and we can’t share them with other people and you can’t share them among yourselves — that’s just the policy. It’s just the copyright policy.

So within the F2907 standard, the new one, the sling standard is referencing the ANSI standards Z535 and there are three separate ones that it’s referencing.

You don’t need these standards if you’re not designing your own labels or if you’re not designing your own instruction manuals necessarily, if you’re purchasing from us, or if you are using our template, then we’ve already covered this.

But I’ll tell you what these three standards are, and I’ve found that casresource.com is the least expensive place I’ve found to purchase it and I do think that they’re about $92 each on that website so it’s not inexpensive to purchase all three standards.

First of all there’s a ANSI Z535.1-2022. This defines your safety colors and the requirements for colors. This is where you’re you going to find the Pantone color for safety orange being 151C, for example. That’s all included in there. And OSHA adopts these standards as well and in various organizations use this particular ANSI test within their standards-setting organizations.

ASTM International — they set the standard for consumer products. ANSI sets a different set of standards.

Another standard you’ll need if you are designing your own labels is the Z535.4-2011. This defines the typefaces that you can use when you’re making the labels, what the ratios of those typefases have to be, the layout of the text and how the spacing has to be, and things like this. The typeface requirements though, and I just want to call your attention to this with this particular standard — they require a certain size typeface based on how far you’ll be viewing the label, but it’s important that when you are following the standard for the SIZE of your typeface you are referencing the ASTM standard. Because if you use the ANSI standard for the height of your text — this is a little confusing — then you won’t be compliant.It’s a discrepancy. The subcommittee decided to keep the text on the warning label larger even though they’re referencing the ANSI standard but this tells you what kind of typefaces you can use, what the layout needs to be, and what are your spacing requirements for that typeface.

Last of all, there’s the ANSI standard Z535.6-2011. This talks about product warning in instructional manuals. Now, if you are going to simply use your graphic for your warning label in your instructional manual, then you’re good to go. You don’t need to include the orange; you can simply use black and white or white and black or or contrasting colors for that warning bar, but if you’re going to simply just use that format and print it in your instruction booklet, then you don’t need to know about the rest of this.

However if you would like to format a little bit differently in your instructional manual, then you’re going to want to get ANSI Z535.6-2022and that just defines requirements and gives examples of how you need to format the warning labels and warning statements in your product instructional manual. The only thing
I will say that’s in there if you are not purchasing the standard is that the requirement is (common sense) make sure that you place the warning statements in the most logical place for your consumer. For instance, before other instructions.

So if you want to assemble the sling a whole bunch and then you want to talk about the warnings as you place the baby into the carrier then that might be an adequate place. You can put them prior to the whole thing but you don’t wanna place them at the end of the instruction manual. That would not be in line with the standard.

If you need more compliance support, or you need help interpreting the standards, then drop me an email: director@babycarrierindustryalliace.org. We offer support to our members from across the globe. Not only for United States Compliance but also Canadian compliance and compliance for places across the world. If we do not have the information that you need, we can help you find it. And we offer compliance consultations to our members at a very low cost and I’m always available to answer questions via email and short phone calls or video calls it can be complicated to interpret the standards. If you would like to talk about the standards I just need proof of purchase that I can ensure I’m not violating any copyright laws by sharing the standard with you if you don’t already own it. But I am more than happy to go through the standards with you and walk you through the pieces of it because I understand they can be confusing and that’s an awful lot to consume.

So. If you have any questions do reach out and watch your email for information about those labels and thank you for your ongoing membership and support! I hope you have a great day. Keep an eye on the blog for lots of conversations about this and we will be updating our website in the near future to help make all of our resources more intuitive fine but for now if you want to access those compliance services I will be updating our compliance checklists ASAP. This week. BUT. If you want to download any of our compliance services of compliance checklists you’re going to log into your member portal and click on resources. And then there will be some buttons that you can click on including one for compliance.

Thanks so much, have a wonderful day, and I hope this was helpful.