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Breaking News: Sling Standard F2907 Now Mandatory for the USA!

On Thursday the 12th January 2017, the American CPSC voted and made the ASTM F2907 Sling Standard mandatory for US manufacturers and importers to comply to from Jan 2018.

F2907

This is very exciting news, as it helps to reinforce safe carrier manufacturing and brings this standard inline with the already mandatory ASTM Structured Carrier Standard F2236.

For Aussie sling/wrap/hybrid carrier manufactures, this change doesn't have a major impact.  In Australia, besides the need to comply to some Aussie textile labeling requirements, there is no requirement to safety test our baby carriers to any standards, particularly the international baby carrier testing standards (managed by the US ASTM or the European CEN).

However, at Global Tapestry we have chosen to test to these, and our Inoshi Baby Carrier has passed the ASTM F2907 and the CEN TR-16512 standards!

The Baby Carrier Industry Alliance (BCIA) has played a major role in getting F2907 (and other) standards across the line - we thank them for all their fabulous work and effort in getting to this great outcome!  You can become a BCIA member and help this great organisation to represent babywearers and the babywearing industry across the globe.

Did you know that I've been asked to present a talk at this year's Babywearing Collective Conference about the babywearing testing standards and Aussie manufacturing industry?  The talk will be held on Saturday 15th July in Brisbane - stay tuned for more details.

          

Want to know more about ASTM F2907?  Keep reading...

  • The F2907 Sling Standard covers baby carrier slings, wraps (woven and stretchy) and hybrid baby carriers where a child could recline in it.  
    • The standard has been around for 5+ years and has been voluntary up to now.
    • The standard includes weighted tests, chemical and fire testing, and details specific wording required for warning labels and booklet.  It doesn't test for suffocation/asphyxiation, ergonomicnesss of a carrier, nor does it specify sewing requirements.
  • The standard is written and independently maintained by ASTM - an American standard and testing authority which many countries source from (Australia tends to refer to the SAI Global standards). 
  • The American Consumer Product Safety Commission (CPSC) is a government based organisation (a bit like our ACCC) which determines which ASTM standards should become mandatory or not.  The CPSC also writes product and safety recommendations (a bit like our Product Safety Australia) and implements the American product legislation.
  • On the 12th January 2017, the CPSC voted to make the current voluntary ASTM F2907-15 standard as mandatory.  The CPSC made the following caveats:
    • They have made the additional requirement that the warning labels required in the standard are now "attached along all sides of the label when affixed to the product" (not full wording) as the standard only requires one side to be attached.
    • They have granted a 12 month grace/implementation period (ending Jan 2018) for businesses to come up to speed on the standard and comply to it.
  • This means that all US manufactures and importers who make slings/wraps/hybrid carriers, need to start working towards their carriers being tested over the next 12 months - because come Jan 2018, all slings/wraps/hybrid US carriers made after that date must comply with F2907.

So what does this mean for Aussie Manufacturers?

Not much really...  This mandatory ruling doesn't follow through to Australian manufacturers.  Australia doesn't have any of our own baby carrier standards to follow, instead we can choose to follow the ASTM or CEN (European) standards if we want too (which Global Tapestry has chosen to do).

But if F2907 is now mandatory for the US market, doesn't this mean that international manufacturers selling into the US must also comply to this standard?

Well, this is where it gets a bit tricky, and each business should seek out their own legal input.  The ASTM writes the standard, but they don't make it mandatory - it's the US government/CPSC that makes it mandatory.  And as they can only govern their own country/people, they can't really demand that other countries comply to their laws. Instead, they say that "US Manufactures and US Importers distributing products in the US" must comply to these standards.

"US Manufacturers" is understandable, but "US Importers"?  Well, the importer is the person who is bringing the product into the US.  If an Aussie business wholesales their product and exports it to the US, the US importer would be the business/retail store bringing in this product to distribute.  When an Aussie business sells one product to a US consumer for self-use, the consumer is classed as the importer.  So, in other words for products made in another country and imported into the US, it's the responsibility of the US retail store or consumer to test the wrap/sling/carrier to F2907... We've chosen to test our Inoshi to the US and EU standards to remove the "importers" need to so this.

So what does this mean for the babywearing market as a whole?

Only time will tell what this truly means, but this is what I think we will start seeing...

  • WARNING LABELS:  The most visible difference we will see on the tested slings, wraps and hybrid carriers will be the inclusion of big warning labels.  The standard requires these to be clearly visible, so these labels will probably stand out like a beacon (like on the tales of wraps or ring slings - the Inoshi has them on the belt). These labels need to be attached on all sides (which we already do on the Inoshi), so people will no longer be able to cut them off.
  • SAFER PRODUCTS:  The whole aim of the standard is to see safer products made, and products that don't pass testing being removed from the market.
  • BUSINESS CLOSURES:  Unfortunately, I think we will also see some of the good smaller US businesses closing down (such as handweavers or WAHM businesses). Testing is expensive, and for businesses who have small batch runs, it possibly won't be cost effective for them to test their products, meaning they might close down or make other textiles or just fabric.
  • PRICE CHANGES:  Sling/Wrap/Carrier prices might change to accommodate the extra costs of testing (our Inoshi prices won't change as we've already factored in these costs)
  • PRODUCT VARIETY:  I think this will be one of the biggest changes, particularly to babywearing products seen as an "art form".  
    • One of the grey areas is the CPSC's requirement is to test each product that has a "material change".
    • What's a material change?  Well, understandably due to the infinite number of possibilities, there is no clear definition for this, so each manufacture has to self-determine what it means to them.  However, in general it refers to a change in something between product A and product B that could result in different test outcomes (such as using different material content or different product sizes).
      • At Global Tapestry, we saw a material change as different material/yarn types.  This is why we only use Little Frog 100% cotton wraps for our Inoshis, because if we also used, say Little Frog cotton/bamboo wraps, we saw this as a material change and felt we would need to do a second round of testing, which would cost more money.
    • Because of this "material change" requirement for the US manufactures, I think we will start seeing a shift in product variety and possibly increased batch numbers.  Each time a manufacture chooses to "change their materials" (whatever they deem this to be), they would need to retest their product, which means more costs.  
      • EG/  Pre-F2907 a wrap business may have produced 10 materially different yarn combos.  Post-F2907 they might chose to only do 3 materially different yarn combos to reduce the number of times they need to test and therefore reduce their testing costs.
      • EG/  Pre-F2907 a sling business may have made 20 limited edition slings.  Post-F2907 they might choose to release 50 limited edition slings to spread out testing costs.
    • We think more international business will start testing to F2907 and we'd love to see more Aussie businesses jumping on board too!

Overall, F2907 becoming mandatory is exciting and great news!  We're sure there will be some teething issues and some changes to the industry, but anything that makes babywearing products safer, the better babywearing will be!

So what do you think?  What other changes do you think might happen?  We'd love to hear your thoughts, so leave us a comment below!

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