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Last reviewed: September 2026 · Copy link
CPC for infant bath tubs (16 CFR part 1234)
Why infant bath tubs needs third-party testing
Bath tub failures — tipping, collapsing supports, drainage faults — create drowning and scald risks for infants left even momentarily unattended. That hazard history is exactly why Congress directed the CPSC to make the voluntary ASTM F2670 mandatory for every infant bath tubs manufactured or imported on or after the rule’s effective date.
Third-party testing at a CPSC-accepted laboratory is not optional here: certification for children’s products is only valid when the testing behind it was performed by an accepted lab for that rule. Keep the report — marketplaces and the CPSC both ask for the pair.
What the standard actually tests
- Testing covers stability, structural integrity under load, drainage performance, and restraint or support features where fitted.
- Permanent product marking and a consumer registration attachment so owners can be reached in a recall (16 CFR part 1130 requirements).
- Tracking labels on the product and packaging: manufacturer, location, and date of manufacture (CPSIA section 103).
- Your test report should map results to the standard’s clauses — the CPC cites the rule, the report proves it.
Issuing the certificate and selling on marketplaces
You — the importer for imported goods, or the domestic manufacturer for US-made goods — issue the CPC in your own name, citing 16 CFR part 1234. Amazon and other marketplaces routinely request the CPC and test report for nursery listings, sometimes on short notice, and suppliers’ certificates are not a substitute for your own.
Questions people ask
Does every infant bath tubs need its own test report?
Products that are identical in all relevant respects can share testing, but a different factory, materials, or construction generally needs its own test. Ask your laboratory to define the testing group.
Do collapsible tubs pass the same tests?
Yes, with additional folded-to-unfolded cycle and locking tests where the design collapses. Confirm the conversion clauses with your laboratory.
Is a bathtub for toddlers still this rule?
Infant bath tubs target the infant age range; toddler bath products may fall outside part 1234 but can still be children’s products needing a CPC for other rules.
Do registration cards really matter?
Yes: durable infant and toddler products must include a consumer registration card and permanent model/date marking under 16 CFR part 1130. Missing registration cards are a common listing and recall-notice failure.
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