Clothing Storage Units (CSU) Regulation Update

Vol. 1342 | 14 Mar 2023

The issue of safety incidents caused by young children climbing on unsecured furniture items has been a high-profile topic for a number of years.

In November 2022, the CPSC issued 16 CFR 1261, a mandatory regulation that imposes test and labeling requirements on Clothing Storage Units (CSU) greater than 27” in height¹. This CFR comes into force on May 24, 2023.

In December 2022, Congress approved the STURDY Act, which also addresses the same issue, but which requires CPSC to promulgate an objective standard to cover CSU with a minimum height of 27”, warning requirements as per the latest ASTM F2057, tests that stimulate children’s weight up to 60 lbs and others to account the adverse effect of carpeted surface on the stability of CSU. Based on the timeline contained with the Act, it will likely become a law in the second half of 2023.

In January 2023, the ASTM test standard cited in the STURDY Act, ASTM F 2057, was recently updated to the 2023 version.  This version includes updates driven by the requirements of STURDY:

• Increase the test weight used in stability tests from 50 lbs to 60 lbs (approx. body weight of children aged six years old)
• New test to address the impact of carpeted surfaces on the stability of CSU and the dynamic force from possible interaction of a child up to six years old

In addition, the 2023 version moves the standard to a closer alignment with 16 CFR 1261, due to the inclusion of a requirement for Interlocks and consideration of the carpeted surfaces on the stability of CSU in using a specific test block during testing.

It remains to be seen how quickly the STURDY Act will move through the various stages of approval and become a Law, and what impact this will have on the status of the CPSC’s CFR. The current advice from the CPSC is that they are unable to comment on how STURDY affect 16 CFR part 1261. CPSC staff are currently evaluating the requirements of STURDY as well as the new ASTM F2057-23 and how it may impact 16 CFR part 1261. At this time, CPSC can only recommend to stay up to date on CPSC’s rulemaking activities by subscribing to Federal Register notices: https://www.federalregister.gov/agencies/consumer-product-safety-commission [federalregister.gov]

In the meantime, Intertek labs around the world are ready to provide testing and assessment services for both the CFR and the updated ASTM standard.

Note¹ - A mass greater than or equal to 57 lbs. with all extendable elements filled with at least 8.5 lbs/ft³, has a total functional volume of the closed storage greater than 1.3 ft³ , and has a total functional volume of the closed storage greater than the sum of the total functional volume of the open storage and the total volume of the open space.

For questions, please contact Rob Burton (rob.burton@intertek.com, +852 37606339).