Dear Stakeholder  
 
The Australian Competition and Consumer Commission (ACCC) is seeking further comment 
as it review s the mandatory safety standard for bunk beds  (the Mandatory Standard ).  
 
We seek your views on : 
• updating the Mandatory Standard  to permit compliance with the latest edition of the 
voluntary Australian standard (AS/NZS 4220:2010 ) 
• allowing  compliance with three  comparable overseas standards  (ASTM F1427 -21; 
BS EN 747 -1: 2012 ; US CFR Part 1513 ).  
 
The Mandatory Standard  could reference each of these  four voluntary standards in full, 
without amendments, or  in part , mirroring  the requirements in the existing mandatory 
standard which currently address the key safety hazards associated with bunk  beds. 
Suppliers would be permitted t o comply with any referenced standard.  
Review of the Mandatory Standard  
The current Mandatory Standard  is the Consumer Protection Notice No.1 of 2003 
Consumer Product Safety Standard: Bunk Beds . It is based on the 1994  edition of the 
voluntary Australian and New Zealand standard,  AS/NZS  4220  Bunk bed s. 
The Mandatory Standard  regulates  the ‘supply’, in trade or commerce, of bunk beds  by way 
of sale, exchange, lease, hire or hire -purchase  
Bunk beds are those products that are supplied as an item of furniture or part of an item of 
furniture, not including portable bunk beds designed for camping or bunk beds that are built -
in fitments in  caravans, camper trailers, tent trailers, camper vans, motor homes, trains, 
ships, aircraft and other types of conveyances.  
More specifically a bunk or elevated bed is currently defined as:  
(a) A set of components that are assembled or are ready for assem bly into single beds or 
double/single combination beds which will be stacked one over the other; or  
  
(b) Any single bed, other than a hospital bed, where the upper surface of the mattress base 
is at least 800  mm above the floor surface  
Policy options  
The ACCC’s preliminary position is to reference the most current edition of the Australian 
voluntary standard  in a revised Mandatory Standard . In addition  though,  consideration will 
be given to referencing overseas standards.  
The ACCC is considering  updat ing the Mandatory Standard  to permit compliance with the 
following voluntary /mandatory  standards:  
• AS/NZS 4220:2010 Bunk beds and other elevated beds  
• EN 747 -1:2012 +A1:2015 Furniture. Bunk beds and high beds. Safety strength 
and durability requirements  
• ASTM F1427 -21e1 Standard Consumer Safety Specification for Bunk Beds  
• U.S. Consumer Product Safety Commission (16 C.F.R Part 1513) Safety Standard 
for bunk beds  (note this is a mandatory standard in the U.S. based on an earlier 
version of the ASTM standard).   
Option 1 a – Revise the mandatory standard in line with sections of the current 
Australian voluntary standard  
This option would involve referencing  certain  requirements contained in the 2010 version of 
the Australian voluntary standard which address the same key safety requirements in the 
current Mandatory Standard , along with some additional safety requirements that are 
considered necessary for improving th e safety of bunk  beds and reducing  the risk of injury or 
death to bunk bed users.  
The current (2010) version of AS/NZS 4220  contains some clarifications and improvements 
to the safety requirements for bunk beds and elevated beds. These include:  
• Redefining the minimum height of a bunk or elevated bed to include beds the upper 
surface of the mattress base is more than 700mm from the floor (currently 800mm)  
• Improving the strength  and integrity tests for mattress base supports and guard rail 
stability  
• Clarifyin g and simplifying entrapment requirements and guard rail height marking  
• Establishing basic requirements for access openings and access devices  
• Age warnings providing safety recommendations for use.  
Benefit s 
Referencing the current version of AS/NZS 4220  will provide certainty to suppliers and 
remove confusion around the mandatory standard continu ing to reference an outdated 1994 
standard . It will also reduce compliance duplication for suppliers who may choose  to meet 
the requirements of the benchmark 2010 Australian standard in addition to the Mandatory 
Standard.  
Elevated beds which have entered the market at just under the current 800mm 
measurement will be within scope of the revised standard  which would  address falls from 
these products. Protection from weak mattress base supports and guard rails will be 
enhanced with improved strength and durability requirements, also reducing the likelihood 
and instance of falls. Age recommendation warnings on the products will alert consumers to 
appropriate and safe usage.  
Limitations  
This option only allows compliance with selected clauses in the current Australian voluntary 
standard , which is now 12 years old. It does not reference all sections of the Australian 
standard  and does not allow compliance options for suppliers which include references to 
other recognised international standards and regulations, thus denying suppliers choice and 
potentially restricting choice for consumers.  The cost of testing may increase sligh tly given 
the improvements and additional requirements in the revised standard.  
Option 1b – Adopt the entire current Australian voluntary standard  
This option would incorporate the changes identified in Option 1a but would simply reference 
the entire ty of the Australian voluntary standard , AS/NZS 4220:2010 .  
In addition to the improvements listed above a revised mandatory standard would include 
requirements for:  
• Construction – heights and play features  
• Footholds  • Sharp edges and points  
• Stability tests for fastenings and tests for static and impact loads on guard rails and 
access treads  
• Information and labelling  
Benefit s 
Referencing the whole of th e Australian  voluntary  standard would in effect simplify the 
understanding for suppliers of what is required to comply with the mandatory standard. 
Rather than selectively isolating specific sections from the voluntary standard and matching 
requirements be tween the Mandatory Standard  (via the CPN) and the voluntary standard, 
suppliers could comply with the entire voluntary standard.  
Referencing the entire Australian voluntary standard  would establish a greater safety 
benchmark for bunk beds and elevated be ds supplied to the  Australia n market.  
Limitations  
This option does not allow compliance for suppliers who may wish to reference other 
recognised voluntary overseas standards, thus denying suppliers choice and potentially 
restricting choice for consumers. T he cost of testing may increase given the improvements 
and additional requirements in the revised standard.  
Option 2a – Revise the mandatory standard in line with the Australian standard 
as well as comparable sections of overseas standards  
This option would allow compliance with the relevant revised clauses of the Australian 
voluntary standard, as in Option 1a above, in addition to compliance with similar comparable 
clauses of the international standards.  
This would include improvements listed in  Option 1a and the matching requirements in the 
EN standard, ASTM standard and the US CFR regulation.  
Benefit s 
This option would produce the same benefit as listed in Option 1a.  The bulk of b unk beds 
are imported, allowing suppliers to source and sell bunk  beds that comply with international 
standard s would offer consumers greater choice.  This could i ncrease competition in the 
market, reduce prices  and, given there are additional provisions being mandated, improve 
safety.  
Limitations  
This option will have t he same basic limitations as in Option 1a. Suppliers would still have to 
comply with selected sections of the mandatory standard and match the mandatory 
requirements with the respective standards. A doption of this option may create some 
industry confusion about which standard to select when supplying bunks and elevated beds 
into Australia.  
Because of the acceptance of multiple voluntary standards, the enforcement of the amended 
mandatory safety standard could potentially be more difficult for regulators th an the current 
mandatory safety standard.  
 
  
Option  2b – Adopt th e entirety of  the Australian standard and overseas 
standards  
This option would incorporate the changes identified in Option 2a but would simply reference 
the entirety of either the Australian voluntary standard, AS/NZS 4220:2010, EN 747 -1:2012, 
ASTM F1427 -21 or US 16 CFR Part 1513.  
Benefit s 
Referencing the whole of either the Australian standard, the EN standard, the ASTM 
standard or the US CFR would offer choice for suppliers in comply ing with the mandatory 
standard. Rather than selectively isolating specific sections from the voluntary stan dard and 
matching requirements between the mandatory standard (via the CPN) and the voluntary 
standard, suppliers could reference the entire voluntary standards.  
Referencing the entire ty of these standard would establish a greater safety benchmark for 
bunk beds and elevated beds supplied to the Australian market , when compared to the 
current selective nature of the Mandatory Standard . 
Suppliers and consumers would benefit from being able to supply and buy a greater range of 
bunk beds and elevated (high beds)  that comply with trusted overseas standards.   
Limitations  
The cost of testing may increase given the improvements and additional requirements in the 
revised standard . However, as there may be greater competition among test ho uses 
competing in the market for product testing services, the new requirements may push down 
testing prices . 
Because of the acceptance of multiple voluntary standards, the enforcement of the revised 
Mandatory Standard  could potentially be more difficult f or regulators than the current 
mandatory safety standard.  
Option 3 – Revoke the Mandatory Standard  
The Mandatory Standard would be revoked and  suppliers would be required to comply with 
the general provisions of the Australia Consumer Law  (ACL). Most consumer goods in 
Australia are not regulated by mandatory safety standards. Revoking the Mandatory 
Standard  would mean suppliers would still need to have regard to the consumer protection 
provisions of the ACL.  
The ACL provides consumers with specific protections for consumer transactions called 
statutory consumer guarantees every time they purchase goods or services. One of those 
guarantees is tha t goods will be of acceptable quality, meaning they are safe and fit for 
purpose.  Although not enforceable by a regulator, consumer guarantees provide consumers 
with a mechanism to seek redress according to their individual circumstances  
Benefit s 
As part o f general product stewardship, s uppliers sell ing bunk beds  would be able to choose 
how much testing they undertake and to what voluntary industry standards they would 
source  stock to meet. This may be less than the compliance costs associated with diligently 
meeting the requirements of a mandatory standard . This may result in lower priced bunk 
beds and a wider range of products becoming available to Australian consumers. If their 
products meet specific the volunt ary requirements of an industry standard suppliers  could seek to gain a market advantage by market ing their product conform ance to t he voluntary 
requirements of an industry standard .  
Limitations  
The consumer protections provisions in the  ACL may not provi de sufficient incentives  to 
businesses  to ensure their goods offer an acceptable level of safety. Without a mandatory 
safety standard, suppliers will be able to determine the safety levels they consider 
appropriate for their products .  
Regulation that appl ies at the point and time of supply is proactive  as suppliers need to 
invest in good product stewardship  early when  sourc ing products. Deterring the supply of a 
potentially unsafe good s and preventing  their use by vulnerable consumers is more effective 
than a reactive response such as a  voluntary or compulsory recall to remove the goods after 
sale to reduce the risk of injury.  
There is a risk that , without regulation, safety  may decrease over time  as the lack of 
established minimum safety levels for bunk beds in the marketplace  would benefit less 
safety conscious  suppliers  selling unsafe bunk beds . This in turn may  diminish consumer 
confidence  over time . 
Questions  
The ACCC seeks your views on the proposal discussed above and responses to the 
questions below:  
1. Which policy option (option 1 a, 1b,  2a, 2b or 3 ) do you support, and why?  
2. Should the ACCC consider another option? If so, which option and why?  
3. Do you consider that the adoption of the listed  overseas standards f or bunk beds  in 
Option s 1 and 2  is beneficial ? 
4. Do you believe  overseas standards offer a comparable level of safety  to the 
Australian standard ? 
5. Do you support the option to  referenc e the entire (complete) voluntary Australian 
standard or each of  the overseas standards  in Option s 1b and 2b ? 
6. Do you believe allowing the supply of bunks  that comply with overseas standards  in 
Option s 1 and 2  could cause confusion for retailers and consumers ? 
7. Would Option s 1b and 2b introduce administrative issues for suppliers? What are 
these issues?  
8. What other issues in terms of compliance for the industry or your business could 
either of the  options  introduce?  
9. Are there cost issues associated with any of the options?  
Backgro und  
The ACCC administers product safety laws designed to ensure certain consumer products 
are safe.  
Certain products sold in Australia are subject to mandatory safety standards which are 
introduced when necessary to prevent or reduce the risk of injury t o a person. The ACCC 
has an ongoing program of reviewing mandatory safety standards to ensure their 
effectiveness and currency.  
 Current regulatory  context  
Mandatory safety standards may reference voluntary standards (in part or in whole), that 
have been d eveloped by recognised standards making bodies in Australia (i.e., Standards 
Australia) or overseas. These standards making bodies regularly update their standards.  
The ACCC is therefore reviewing the bunk bed  standard so that it references the most up to 
date voluntary /mandatory  standards.  
Your feedback  
The ACCC invites you to comment on this review. Please provide your submissions via 
email to productsafety.regulation@accc.gov.au  by Friday 23 September  2022.   
If you have any  questions  about this consultatio n before the due date , please  email  them  to 
productsafety.regulation@accc.gov.au . 
Thank you for your time and considerat ion.