U.S. CONSUMER PRODUCT SAFETY COMMISSION

Office of Education, Global Outreach and Small Business Ombudsman

RESELLERS GUIDE 

TO SELLING SAFER PRODUCTS

MAKE SAFETY YOUR BUSINESS
Cover image from The Thrift Store Bears: Poems used by express permission of the illustrator, Patricia Woolley, and David Evans, 

in honor of his late wife and author, Olive Evans. Ms. Evans collected stuffed bears from thrift stores and wrote the poems 

to keep her spirits high during her struggle with breast cancer. 

Jim Furmston scored the accompanying music to The Thrift Store Bears: Poems.
TABLE OF CONTENTS

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

The Basics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

You are not required to test your products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What you cannot sell. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

CPSC Can Help You. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

CPSC’s Response to Violations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Product Guides. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Bath Seats. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Bean Bag Chairs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Bunk Beds for Children. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Car Seats/Carriers Combination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Cribs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Drawstrings on Children’s Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Hair Dryers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Halogen Floor Lamps. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Lead in Children’s Products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Lead in Children’s Products Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Mattresses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Phthalates. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Play Yards, Mesh-Sided. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Small Parts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Toy Chests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Toys with Magnets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Walkers (Baby). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

CPSC Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

The electronic version of this document (www.cpsc.gov/resale) provides access to additional helpful information available by clicking on 

the hyperlinks — the letters, words, phrases, and web addresses shown in dark blue provided throughout the document.
INTRODUCTION

The U.S. Consumer Product Safety Commission (CPSC) created this Guide for Resale Stores 

and Product Resellers to help you identify the types of products that are affected and 

to understand how to comply with the law so that you can keep unsafe products out of 

the hands of consumers. Consumers who regularly buy used products may also find this 

information helpful in avoiding products that could harm them or their family.

On August 14, 2008, the President signed into law the Consumer Product Safety 

Improvement Act of 2008 (CPSIA). The implementation of the CPSIA has resulted in dramatic 

changes in the used product marketplace. For example:

• Selling recalled products is now unlawful. 

• The law sets strict limits for lead in paint and for lead content. 

• Most cribs manufactured before June 2011 may not be resold.

• New regulations (mandatory standards) are being put into practice for durable infant 

and toddler products, such as play yards, infant walkers, bath seats, bed rails for 

toddlers, and more.

In light of these new requirements for many consumer products, resellers should closely 

examine their products in inventory prior to resale to make sure that their products are safe 

and compliant with federal laws. This Guide will help you make sound business decisions to 

protect yourself and your customers. 

Please make sure you visit our website at: www.cpsc.gov/resale — for updates on this 

information and to sign up for the email list we created specifically for resale stores and 

product safety. 

www.cpsc.gov 2
 THE BASICS

The CPSC’s laws and regulations apply to anyone who sells or distributes consumer products. 

This includes thrift stores, consignment stores, charities, and individuals holding yard sales 

and flea markets. 

CPSC does not require you to test your products for safety.

CPSC urges you to take a few extra steps when you sell your used products and to follow the 

advice in this Guide to ensure that you are only selling safe products. And while you are not 

required to test your products for safety, resale stores, resellers (including those who sell on 

auction websites), and persons who give away used products for free cannot knowingly sell 

products that do not meet the requirements of the law. If a product is hazardous, or does 

not comply with standards, the product should be destroyed and not be sold or given away 

to others. 

You can protect yourself and your customers by using the resources in this Guide and at 

www.cpsc.gov/resale to screen for hazardous and other violative products. Ignorance of the 

law is not an excuse. But more importantly, as a person and as a business, you do not want 

to sell products that have the potential to cause harm to anyone, especially a child.

Examples: What you cannot sell or offer for sale:

• Children’s metal jewelry that does not comply with the federal limit on lead of 100 

parts per million;

• Products that have been recalled by the CPSC (unless the 

products have been repaired in accordance with the recall);

• Toys and other articles intended for use by children 

and any furniture with paint or other surface coatings 

containing lead over the specified amount;

• Products intended primarily for children age 12 or younger 

with lead content known to be over the specified amount;

• Most cribs manufactured before June 2011 may not 

be resold;

• Durable infant and toddler products, such as play yards, infant walkers, bath seats, 

bed rails for toddlers, and others that are missing parts, appear wobbly or unstable, 

or contain known hazards described in this Handbook; and

• Other products that violate the CPSC’s safety standards, bans, rules, or regulations, 

or that otherwise present a substantial product hazard.

www.cpsc.gov 3
 CPSC CAN HELP YOU

The CPSC would like to help you ensure that the products you sell are safe. You should 

periodically check www.cpsc.gov/resale for updates to the information in this Guide. In 

addition, the CPSC has many tools available to help you stay informed about recalls and 

product safety. (On average, CPSC recalls between 300 – 500 products annually.) 

If you are in the business of reselling products, you are expected to know the laws, rules, 

and regulations that apply to your business, including whether a product you are selling has 

been recalled for a safety issue. It is illegal to sell any recalled product.

• Search Recalls: SaferProducts.gov has a listing of CPSC recalls and consumer reports 

of harm related to consumer products. Review the list of recalled products before 

taking a product into inventory or selling it. You can also receive information about 

CPSC recalls by subscribing to the CPSC’s recall email list. 

• Keep Current: Subscribe to the CPSC’s email list for resale stores and product 

resellers, and keep current on information developed specifically for resale stores at: 

www.cpsc.gov/resale. 

• When in doubt, throw it out! Products used in the nursery, especially cribs and 

bassinets, have caused deaths and have been the subject of numerous recalls of 

millions of units. Do not sell any broken or wobbly nursery furniture or durable infant 

product that is missing parts, even if it has not been recalled. A baby’s life could 

depend on it. The risk is too high. 

• Contact: For questions about regulatory requirements, contact CPSC’s 

Office of Education, Global Outreach, and Small Business Ombudsman: 

Email: Business@cpsc.gov; telephone (301) 504-7999; or contact the CPSC’s Small 

Business Ombudsman at: www.cpsc.gov/smallbiz for additional information and 

guidance for small businesses.

• Contact: For questions about enforcement, contact CPSC’s Office of Compliance for 

inquiries regarding enforcement: Email: sect15@cpsc.gov; telephone: (301) 504-7520. 

www.cpsc.gov 4
CPSC’S RESPONSE TO VIOLATIONS

The CPSC’s goal is to help you avoid future violations and protect your customers—not to 

put you out of business. If you learn that one of the products you sell violates the law or 

presents a hazard, immediately inform the Commission. 

Under the law, it is illegal for retailers to sell or offer for sale a product in violation of the 

CPSIA or other CPSC laws. Our purpose is to ensure these products aren’t being sold, so we 

still need to hear from you if you discover you may have sold one of these products in the 

past. The information you provide us will assist us in developing future outreach programs 

targeting resellers so these hazardous products won’t be sold. When informed of the sale of 

such products, we will work with you to ensure the agency’s response is appropriate under 

the circumstances.

You can report a potentially defective or hazardous product at: www.SaferProducts.gov

or by phone at (800) 638-2772.

THANK YOU

Thank you for working with the CPSC to ensure that the children’s products and other 

consumer products you sell are safe and comply with all applicable product safety rules. 

This publication was developed by the CPSC’s Office of Education, Global Outreach, 

and Small Business Ombudsman. Suggestions, feedback, and additional questions are 

welcomed at: Business@cpsc.gov.

www.cpsc.gov 5
The following guides provide illustrations of safety concerns 

when reselling products. Even if a product is not listed here, 

you should take similar care in reviewing each product 

and consider the potential hazards described in these guides.

Additional product guides will be added over time and distributed 

at www.cpsc.gov/resale. 

PRODUCT GUIDES

www.cpsc.gov 6
BABY BATH SEATS

HAZARDS: Drowning, submersion.

Infant bath seats are used in a sink or tub to provide back and front support to

bathe a seated infant. They are marketed for use with infants between 5 and 

10 months of age. 

There are three primary hazards with baby bath seats that typically occur when 

the child is left unattended, even for a short period of time: the bath seat becomes 

unstable and tips the child over into the water; the child slips through the bath seat 

leg opening into the water; or the child attempts to climb out and falls into the water. 

CPSC staff is aware of 29 deaths associated with baby bath seats and similar products 

during 2006 – 2008.

Mandatory

Standards

Recalls

The mandatory standard for baby bath seats went into effect on December 6, 2010.

Go to: 16 CFR Part 1215.

Check www.SaferProducts.gov for baby bath seat recalls. It is illegal to sell a recalled 

product.

RESELLER RESPONSIBILITY: CPSC staff advises you to destroy bath seats that:

• were made prior to December 6, 2010 before the new safety standard went into effect. (See date 

code stamp on the bottom of the product or contact the manufacturer.); 

• attach directly to the tub floor with suction cups. (Suction cups may have contributed to some

bath seat-related deaths because they failed to adhere to the tub surface, they separated from 

the bath seat, or they were missing);

• are broken or damaged; or

• do not have permanent warnings visible on the product. Warning labels are required by law to 

be fixed to the bath seat to alert parents and caregivers that bath seats are not safety devices 

and that infants should never be left unattended in a bath seat. 

OTHER RESOURCES: Business Guidance for Bath Seats (Infant)

www.cpsc.gov 7

Does not meet

mandatory standards
BEAN BAG CHAIRS

HAZARDS: Suffocation, choking. 

Bean bag chairs made with zippers and foam pellets have resulted in deaths, as 

well as nonfatal incidents. Children have unzipped bean bag chairs, crawled inside, 

inhaled or ingested the foam pellets, and suffocated. Some have unzipped the chairs, 

then pulled out the foam pellets and played with them. The pellets clogged their 

mouths and noses, and they suffocated. Other children choked on the pellets but 

survived. CPSC received reports of 5 deaths and 26 nonfatal incidents associated with 

bean bag chairs. Victims ranged in age from 14 months to 14 years. Since 1996, bean 

bag chairs have been manufactured with zippers that young children can’t open.

The voluntary standard for bean bag chairs requires that chairs intended to be refilled must have a locking zipper 

that opens only with a special tool. Chairs not intended to be refilled must have a permanently disabled zipper or 

no zipper. In addition, the requirements include permanent warning labels for bean bag chairs. The label wording 

differs depending on whether the chairs can be refilled. Durability testing is intended to ensure that materials that 

could tear easily and allow pellets to escape and be inhaled are not used in manufacturing bean bag chairs. 

Recalls Check www.SaferProducts.gov for bean bag chair recalls. It is illegal to sell a recalled 

product.

Voluntary

Standards

Go to: ASTM F1912-98 (reapproved 2009). Voluntary standards are industry technical 

specifications that are developed by industry, government, and consumer representatives.

RESELLER RESPONSIBILITY: CPSC staff advises you to destroy any bean bag chair that has:

• a zipper that can be opened by young children;

• stuffing or pellets coming out of the chair; and 

• seams that can come apart if they are pulled. The foam pellets could escape, posing a hazard to children.

OTHER RESOURCES: Bean Bag Chair Recalls 

www.cpsc.gov 8
BUNK BEDS 

HAZARDS: Strangulation, suffocation, hanging. 

A bunk bed is any sleep structure with at least one mattress foundation more than 

30 inches above the floor. A mattress foundation is the base or support on which you 

place the mattress. Since 1990, more than 70 children have died by strangulation or 

suffocation from entrapment in bunk beds. Most were 3 years old or younger. Some 

children strangled when their bodies, but not their heads, slid between a guardrail 

and the bed frame, leaving their bodies hanging. Some suffocated when they became 

trapped in openings within the footboard or headboard end structures or between the 

bed and the wall. CPSC staff also is aware of incidents of hanging, where some children 

hanged from a top bunk when something they were wearing caught on a vertical 

protrusion as they were climbing out of the bunk.

Recalls Check www.SaferProducts.gov for bunk bed recalls. It is illegal to sell a recalled product.

Mandatory

Standards

The mandatory standard for bunk beds went into effect on June 19, 2000. 

Go to: 16 CFR Parts 1213, 1500, 1513 to review the regulations. (The voluntary standard is 

ASTM F1427, Standard Safety Specification for Bunk Beds.)

RESELLER RESPONSIBILITY: Check the assembled bunk bed, and only sell it if it has all of the 

following safety features. Otherwise, destroy it.

Guardrails on Both Sides of the Upper Bunk:

• One guardrail should run continuously from the headboard to the footboard.

• If a guardrail is not continuous, there should be no openings greater than 15 inches between the end

of the guardrail and either end structure (headboard or footboard).

• There should be no openings larger than 3 1⁄2 inches within, or immediately below, the guardrail.

End Structures:

• The end structures in the upper bunk must not have openings larger than 3 1⁄2 inches. The end

structures in the lower bunk should not have openings larger than 3 1⁄2 inches, unless those openings 

are 9 inches or greater.

Other Requirements:

• Assemble and ensure that the bunk beds have all component parts, including all screws and hardware.

For tubular metal bunk beds, there must be no breaks or cracks in the paint or metal around the welds 

that hold the side rail to the bed frame at all four corners of the upper and lower bunks.

• There should be no vertical protrusions or projections, such as ladder stiles or corner posts, that extend

more than 3/16 inch above the top of any end structure, guardrail, or other part of the upper bunk.

• There should be a warning label on the bed that describes the strangulation hazard from children

becoming entangled from items attached to or hanging from the upper bunk.

• The mattress, if there is one, should match the size specified in the warning label on the bed.

Specifically, the top of each guardrail should be at least 5 inches above the top of the mattress and the 

top of each end structure (headboard and footboard) should be at least 5 inches above the top of the 

mattress for at least half of the mattress length. 

OTHER RESOURCES: Business Guidance for Bunk Beds 

www.cpsc.gov 9
CAR SEATS/CARRIERS COMBINATION

HAZARDS: Skull fractures, concussions, cuts, scrapes, bruises. 

A combination infant car seat/carrier is a product that can serve as both a car 

seat and as a hand held infant carrier. This safety information summary addresses 

when an infant carrier is used outside of a vehicle. (The National Highway Traffic 

Safety Administration (NHTSA) provides advice about the safety of car seats used in 

vehicles at NHTSA — Parents Central.)

Most injuries and deaths associated with carrier seats outside of vehicles result 

from falls when an adult carries the car seat with the baby inside. A number of 

CPSC recalls were due to the handles or locks breaking, releasing and/or rotating 

unexpectedly allowing an infant to fall to the ground or be ejected on their own 

or when an adult carrying the seat falls down. These falls resulted in skull fractures, 

lacerations, broken bones, bruises, and scratches.

In 2010, there were an estimated 16,900 carrier-related injuries (excluding motor vehicle incidents) treated in 

U.S. hospital emergency departments. Between 2006 and 2008, there were 35 deaths among children less than 

5 years old associated with infant carriers and car seat carriers. 

Recalls Check www.SaferProducts.gov for CPSC infant carrier recalls and SaferCar.gov for NHSTA 

car seat recalls. It is illegal to sell a recalled product. 

Voluntary

Standards

The voluntary safety standard for hand held carriers for use outside of vehicles is found at: 

ASTM Voluntary Standard F2050. Voluntary standards are industry technical specifications 

and are developed by industry, government, and consumer representatives.

RESELLER RESPONSIBILITY:

• Contact the manufacturer — if you have a CPSC or NHTSA recalled car seat/carrier, 

it may be able to be repaired to make it safe. Otherwise, destroy it.

• Check with NHTSA to see if the expiration date on the infant carrier has passed.

OTHER RESOURCES: CPSC Safety Information for Hand Held Infant Carriers; NHTSA Parents Central — Using a 

Secondhand Car Seat

www.cpsc.gov 10
CRIBS

HAZARDS: Suffocation, strangulation. 

NEW: On June 28, 2011, new and improved safety regulations went into 

effect for full- and non-full-size cribs. These new mandatory rules include the 

elimination of drop sides, and greater structural integrity and crib strength. 

Do not assume that all non-drop-side cribs (even those where the drop-side 

has been immobilized) comply with the standard. They do not. No cribs 

may be manufactured, sold, or resold that do not meet these more stringent 

standards.

Definitions:

• A full-size crib is one that has interior dimensions of 28 + 5/8 inches wide, 52 + 3/8 inches long 

(within the range of 2 inches). 

• A non-full-size crib can be either smaller or larger than these dimensions and include oversized, 

specialty, undersized, and portable cribs that have rigid sides. 

Between November 2007 and April 2010, CPSC had reports of 35 deaths in cribs due to structural problems, 

many of which were related to drop-side fatalities and/or gaps opened up by loose/missing screws, or other 

hardware failures. Thirty-four of the 35 deaths were due to head/neck/body entrapments. 

Mandatory

Standards

Recalls

The mandatory standard for full- and non-full-size cribs went into effect on June 28, 2011. 

Go to: 16 CFR Parts 1219, 1220.

Check www.SaferProducts.gov for crib recalls. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY:

• Destroy any full- or non-full-size crib (with or without drop sides) manufactured before June 28, 2011 

unless you have written proof that the crib meets the standard above. (NOTE: Absolutely no drop side 

cribs in the used marketplace — even if immobilized with new hardware — can meet the standard and, 

therefore, must be destroyed.) Each full-size and non-full-size crib must have a date stamp marked 

permanently on the product.

• For cribs manufactured after June 28, 2011, assemble and make sure that the cribs have all component

parts, including all screws and hardware and check for recalls.

• Do not accept cribs that do not comply with the federal standard.

A non-full-size crib does not include products such as play yards, cradles, baby baskets, and bassinets with 

mesh/net/screen siding. These products may be subject to other regulations. See additional CPSC resellers’ 

guidance on your product.

OTHER RESOURCES: Crib Information Center; Business Guidance For Cribs (Full-Size) And Cribs (Non-Full-Size)

www.cpsc.gov 11
 DRAWSTRINGS ON CHILDREN’S CLOTHING

HAZARDS: Strangulation.

Drawstrings are non-retractable cords, ribbons, or tapes of any material to pull together 

parts of upper outerwear to provide for closure. The CPSC regulation defines “upper 

outerwear” as “clothing, such as jackets and sweatshirts, generally intended to be worn on 

the exterior of other garments.” 

Young children can be seriously injured or killed if the upper outerwear they are wearing 

catches and snags on other objects. CPSC staff is aware of 18 deaths and 38 nonfatal 

incidents associated with neck/hood drawstrings on children’s outerwear between January 

1985 and September 2009, involving children 18 months to 10 years of age. Of these, 

the most common incident scenarios involved drawstrings getting entangled on 

playground slides. Typically, as a child descended the slide, the toggle or knot on the 

drawstring got caught in a small space or gap at the top of the slide. Examples of catch 

points include: a protruding bolt or a tiny space between the guardrail and the slide 

platform. This can present a strangulation risk and has resulted in death. Incidents have 

also occurred when the long, trailing drawstring at the waist of a jacket was caught on 

the closed door of a moving school bus.

Substantial

Product

Hazard

Recalls

In July 2011, the Commission determined that hood and neck drawstrings on children’s 

upper outwear present a strangulation hazard that is a substantial product hazard. 

Go to: 16 CFR Part 1120. The Commission can order retailers, including resellers, to 

recall a product deemed to be a substantial product hazard.

Check www.SaferProducts.gov for recalls of clothing with drawstrings. 

It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: Inspect children’s upper outwear for the:

• hood and neck area, sizes 2T to 12 — completely remove the drawstrings; 

• waist and bottom area, sizes 2T to 16 — modify or remove the drawstrings so that they are:

— limited to 3 inches outside the drawstring channel when the garment is expanded

to its fullest width; 

— free of toggles, knots, and other attachments at the free ends of drawstrings; and

— are one continuous string and bar tacked (i.e., stitched through to prevent the

drawstring from being pulled through its channel).

The restrictions on drawstrings do not include: underwear and inner clothing layers, pants, 

shorts, and skirts that are not intended for the upper portion of the body.

OTHER RESOURCES: Drawstrings Summary; Recalls Of Clothes With Drawstrings; FAQs For Drawstrings

www.cpsc.gov 12
 HAIR DRYERS

HAZARDS: Electric shock, Electrocution (death). 

A hand held hair dryer is a portable electrical appliance that routinely contains 

open-coil heating elements that are uninsulated, electrically energized wires, 

across which a fan blows air. Electric voltage is still present when the hair dryer 

is plugged in, even if the switch is in the “off” position. Without the immersion 

protection device shown in the illustration to the right, a dryer that is dropped 

accidentally into water, such as in a sink or bathtub, can electrocute anyone who 

is in the water or who touches the water.

Most new hand held hair dryers have immersion protection devices. Many used 

hand held dryers do not. This immersion protection is required even if a hair 

dryer is intended for professional use only.

The standards have been very effective in reducing deaths and electric shock injuries from hair dryer immersion or 

contact with water. Before the initial safety standards took effect in 1986, a total of 110 electrocutions reportedly 

were due to hair dryer immersions or water contact. Three hair dryer-related electrocutions were reported from 

1998 to 2007, none of which were associated with immersion or contact with water.

Substantial

Product

Hazard

Recalls

Hair dryers without immersion protection are on the CPSC’s list of substantial product 

hazards under 16 CFR Part 1120 if they do not comply with (1) section 5 of Underwriters 

Laboratories’ (UL) Standard for Safety for Household Electric Personal Grooming Appliances, 

UL 859, 10th Edition, approved on August 30, 2002, and revised through June 2010, or 

(2) section 6 of UL’s Standard for Safety for Commercial Electric Personal Grooming 

Appliances, UL 1727, 4th Edition, approved on March 25, 1999, and revised through 

June 25, 2010. Go to: UL Standards 859 and 1727. The Commission can order retailers, 

including resellers, to recall a product deemed to be a substantial product hazard.

Check www.SaferProducts.gov for hair dryer recalls. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: CPSC staff advises you to destroy any hair dryer that 

does NOT have:

• an integral immersion protection device, which is a large block-shaped plug at the end

of the cord that contains some type of circuit interrupter. The picture to the right shows 

a power cord with an integral circuit interrupter at the plug end; and

• the certification mark of a recognized testing laboratory, such as UL (Underwriters 

Laboratory) on the hair dryer itself.

OTHER RESOURCES: Business Guidance for Hand Held Hair Dryers

www.cpsc.gov 13

Hand Held Hair Dryer

(meets UL standards)
HALOGEN LAMPS

HAZARDS: Fire. 

Halogen torchiere floor lamps are freestanding lamps that have a shallow bowl-shaped light 

fixture mounted on top of a 6-foot pole and are illuminated by a tubular halogen bulb. A 

halogen light bulb can heat up to nearly 1,000 degrees Fahrenheit. Because of this, flammable 

materials, such as curtains or clothing that come into contact with the bulb can catch fire. 

From 1992–1999, the CPSC received reports of at least 270 fires and 18 fire-related deaths 

involving halogen torchiere floor lamps. Halogen torchiere floor lamps manufactured after 

February 5, 1997 that meet voluntary safety requirements are made with a wire or 

glass guard. The guard fits over the glass bulb shield that covers the light bulb and 

reduces the potential fire hazard. The guard makes it harder for flammable 

materials to come into contact with the light bulb and catch fire.

Recalls Check www.SaferProducts.gov for halogen torchiere lamp recalls. It is illegal to sell a 

recalled product.

Voluntary

Standards

Go to: UL Standard 153, Standard for Portable Electric Luminaires. Voluntary standards 

are industry technical specifications and are developed by industry, government, and 

consumer representatives.

RESELLER RESPONSIBILITY: CPSC staff advises you to destroy any halogen lamp if:

• There is no wire or glass guard over the glass bulb shield in the bowl at the top of the lamp. 

The top of the guard should be 3 inches from the glass bulb shield;

• The bulb wattage for the tubular halogen light bulb is more than 300 watts, even if the 

original label on the lamp says that a 500-watt bulb can be used;

• The plug is not polarized (one blade wider than the other); 

• The cord has mechanical damage; or

• There are signs of corrosion, bent, or loose parts. Any of these may indicate a malfunctioning 

or potentially hazardous lamp.

OTHER RESOURCES: Halogen Lamps Recalls 

www.cpsc.gov 14

Glass Bulb Shield

Wire Shield
 LEAD IN CHILDREN’S PRODUCTS

HAZARDS: Brain damage, physical and mental delays and disorders.

Children’s products, those designed and intended primarily for children 12 

years of age or younger, cannot be sold if they do not meet the following 

lead limits:

• 90 parts per million (ppm) lead in paint or other surface coating for 

toys, other articles intended for use by children of any age, and on 

all moveable painted furniture.

• 100 ppm lead content limit in any accessible component part, 

unless otherwise excluded (see next page). 

Toys, clothes, furniture, books, jewelry, blankets, games, strollers, and footwear may all be considered children’s 

products.

Lead poisoning can cause irreversible brain damage, delay mental and physical growth, and cause behavior, 

attention, and learning problems. Children are particularly at risk because their developing bodies can absorb up 

to 50 percent of the lead to which they are exposed. This exposure occurs because children often put their hands 

and other objects in their mouth that can have lead dust on them. In 2012, the Centers for Disease Control 

estimated that about 450,000 children have lead levels higher than the CDC’s recommendation limit.

Recalls Check www.SaferProducts.gov for lead recalls. It is illegal to sell a recalled product.

Mandatory

Standards

(1) Lead in Paint Rule: 16 CFR Part 1303.

(2) Total Lead Content in Accessible Component Parts: 15 U.S.C. § 1278a or Sec. 101 of 

the Consumer Product Safety Improvement Act of 2008, (CPSIA).

RESELLER RESPONSIBILITY: Although you are not required to comply with the lead limits, 

CPSC staff encourages you use several strategies to protect your customers:

• Resellers are not required to test suspected products. However, resellers cannot knowingly sell any 

children’s product or painted furniture that does not comply with the new lead limits. Check for recalls, 

and if the product has been recalled, follow the recall instructions, or destroy it. If you have other reasons 

to suspect there is excessive lead based on your knowledge of the product, destroy it.

• For products with high resale value, or where you have additional safety concerns, contact the 

manufacturer for verification that the product meets the lead limits. Ask for a “Children’s Product 

Certificate.” Lead screening can also be done with an x-ray fluorescence (XRF) machine. Lead testing kits 

sold commercially are generally unreliable and should not be used.

OTHER RESOURCES: Business Guidance for Lead in Paint And Total Lead Content

www.cpsc.gov 15
LEAD IN CHILDREN’S PRODUCTS SUMMARY

With the exception of children’s metal jewelry, thrift stores and other similar stores are excluded from having to 

comply with the limits on lead content for used children’s products. (To take advantage of this exclusion, the goods 

being sold must be truly used, donated, and/or obtained from someone who actually used the items and may not 

be items that were originally purchased for the intent of resale only.) 

PRODUCTS THAT MAY HAVE LEAD RESELLERS GUIDANCE

Children’s metal jewelry. Test, contact the manufacturer, or do not sell.

Children’s clothes with rhinestones, metal or vinyl/plastic 

snaps, zippers, grommets, closures, or appliqués.

Best to test, contact the manufacturer, or do not 

sell.

Children’s jewelry and other items made entirely of:

• Surgical steel,

• Precious metals, such as gold (at least 10 karat), sterling 

silver (at least 925/1,000),

• Precious and semi-precious gemstones (excluding a list of 

stones that are associated in nature with lead), or

• Natural or cultured pearls.

OK to sell.

Children’s clothes, blankets, and other items made entirely 

of:

• Dyed or undyed textiles (cotton, wool, hemp, nylon, etc.),

• Dyed or undyed yarn.

Nonmetallic thread, trim, hook-and-loop (Velcro) and 

elastic.

OK to sell.

Children’s books printed after 1985, which are printed 

conventionally and intended to be read (as opposed to 

used for play).

OK to sell; however, books with metal spiral 

bindings have been recalled for lead paint.

Vintage children’s books and other collectibles not 

considered primarily intended for children.

OK to sell, but check for recalls.

Certain educational materials, such as chemistry sets. OK to sell, but check for recalls.

Items made entirely of wood (without paint, surface 

coatings, or hardware).

OK to sell, but check for recalls.

Mirrors that are part of furniture articles, to the extent 

that they bear lead-containing backing paint.

OK to sell, but check for recalls.

Artists’ paints and related materials. OK to sell, but check for recalls.

Metal furniture bearing factory-applied (lead) coatings, 

such as powder coatings.

OK to sell, but check for recalls.

Bicycles and other related products (such as trailer bicycles 

and jogger strollers).

OK to sell, but check for recalls.

COMMONLY RESOLD CHILDREN’S PRODUCTS THAT MAY CONTAIN LEAD

www.cpsc.gov 16
MATTRESSES

HAZARDS: Fire.

Mattresses, either as a set with a foundation or labeled for sale 

alone, must meet the CPSC’s flammability regulations designed 

to limit the spread and intensity of a fire ignited by open-flame 

sources, such as candles, matches, and lighters and by cigarette 

ignition. 

Mattresses contain a substantial amount of flammable material. If 

a mattress that does not meet the open-flame regulation ignites in 

a bedroom fire, the mattress can burn rapidly and reach dangerous 

flashover conditions within a few minutes. (Flashover is the point 

at which the entire contents of a room are ignited simultaneously 

by radiant heat, making it impossible for occupants to escape from 

a fire.) The pictures show a mattress that does not meet the open-flame standard (noncompliant) and one that 

does (compliant) 3 minutes after each was set on fire. 

Many mattress fires are caused by children playing with open flames, such as candles, lighters, and matches, or 

when candles are left unattended. The mattress regulation is estimated to prevent as many as 270 deaths and 

1,330 injuries each year.

Recalls Check www.SaferProducts.gov for mattress recalls. It is illegal to sell a recalled product.

Mandatory

Standards

The mandatory standard addressing open-flame ignition went into effect on July 1, 2007. 

Go to: 16 CFR Part 1633. The mandatory standard addressing cigarette ignition went into 

effect on June 22, 1973. Go to: 16 CFR Part 1632.

RESELLER RESPONSIBILITY: Destroy mattresses and mattress sets manufactured, imported, or 

renovated:

• after July 1, 2007, and that do not have a label certifying that they meet the standard. Every mattress

and foundation must bear a permanent, conspicuous, and legible label in English. If a mattress was made 

before 2007, it would be good practice NOT to resell such a product. 

• where the mattress or foundation is not intended to be sold separately and the component to be sold fails

to meet the requirements of the standard. The label states whether the mattress is intended for use with a 

foundation, without a foundation, or with or without a foundation.

OTHER RESOURCES: Guidance for Mattresses and Mattress Pads

www.cpsc.gov 17

Non-Compliant Compliant
 PHTHALATES IN CHILDREN’S TOYS AND CHILD CARE ARTICLES

HAZARDS: Development effects. 

Phthalates are a group of chemicals that are used, among other things, to make 

vinyl and other plastics soft and flexible. As of February 10, 2009, Congress 

permanently banned three types of phthalates (DEHP, DBP, BBP)1 in any amount 

greater than 0.1 percent in (1) children’s toys and (2) certain child care articles.

• A children’s toy is designed or intended for a child who is 12 years old or 

younger for use when playing. General use balls, bath toys/bath books, dolls 

and inflatable pool toys are examples of toys that are covered by the law and 

might contain phthalates. Bikes, musical instruments, and sporting goods 

(except for their toy counterparts) are not considered toys and are not affected by the ban.

• A child care article is designed or intended for a child who is 3 years old or younger, to use for sleeping 

or feeding or to help a child who is sucking or teething. Bibs, child placemats, cribs, booster seats, 

pacifiers and teethers are child care articles that are covered by the law and might contain phthalates.

Congress has also banned (on an interim basis) three additional types of phthalates (DINP, DIDP, DnOP)2

 in any 

amount greater than 0.1 percent in (1) child care articles and (2) toys that can be placed in a child’s mouth, for 

example: squeeze toys, teethers, bath toys, and inflatable pool toys.

Recalls Check www.SaferProducts.gov for phthalate recalls. It is illegal to sell a recalled product.

Mandatory

Standards

Section 108 of the Consumer Product Safety Improvement Act of 2008 (CPSIA) 

Additional requirements related to the ban on cetain phthalates were added in section 5

of H.R. 2715, Pub. L. No. 112-28 (August 12, 2011), which amended the CPSIA.

RESELLER RESPONSIBILITY: You can use several strategies to comply with the phthalates ban:

• Resellers are not required to test suspected products. However, resellers cannot knowingly sell any 

children’s toy or child care article that does not comply with the ban on phthalates. Check for recalls and 

if the product has been recalled, follow the recall instructions or destroy it. If you have other reasons to 

suspect the product contains banned phthalates, destroy it.

• Your safest course is not to sell or accept certain products, unless you know they don’t contain banned 

phthalates. CPSC’s enforcement efforts will be focused on the products most likely to pose a risk of 

phthalate exposure to children, such as bath toys and other small, plastic toys, especially those made 

of polyvinyl chloride (PVC)that are intended for young children and can be put in the mouth.

1

DEHP: di-(2-ethylhexyl) phthalate; DEP: dibutyl phthalate; BBP: benzyl butyl phthalate.

2

DINP: diisononyl phthalate; DIDP: diisodecyl phthalate; DnOP: di-n-octyl phthalate.

OTHER RESOURCES: Phthalates Information

www.cpsc.gov 18
PLAY YARDS, MESH SIDED

HAZARDS: Suffocation, strangulation, choking.

Mesh-sided play yards (or play pens) are made of fabric or mesh side panels that 

attach to a rigid frame structure, including a floor. They are intended primarily 

for children who cannot climb out. 

The CPSC is aware of a total of over 2,100 incidents associated with play yards 

that occurred between November 2007 and December 2011, including 

60 deaths and 170 injuries. About 89 percent of the incidents, as well as one 

death, were related to the unexpected collapse of the play yard’s side rail. Since 

2009, the CPSC has issued four recalls of more than 1.4 million play yards. 

Mandatory

Standards

Recalls

Voluntary

Standards

A mandatory standard for play yards went into effect in February 2013. 

Go to: 16 CFR Part 1221. 

Check www.SaferProducts.gov for play yard recalls. It is illegal to sell a recalled product.

Go to: ASTM Voluntary Standard F406-12A. Voluntary standards are industry technical 

specifications and are developed by industry, government, and consumer representatives.

RESELLER RESPONSIBILITY: Verify that all of the following safety features 

are present. If not, destroy the play yard.

Warning labels are present and state that the sides should never be left in the down 

position. (In the down position, the side forms a pocket that an infant can roll into 

and become trapped, causing the child to suffocate.) 

The top rails:

• with a hinge in the center, must lock automatically when the rails are lifted 

into the normal use position. (If unlocked, the hinge may collapse, and the 

top rails can form an acute V-shape that can entrap a child’s neck and cause 

the child to strangle);

• vinyl covering has no tears or holes. (A teething infant can chew off pieces 

of the vinyl covering of a play yard’s railing and choke).

The mesh:

• has openings (weave) that are less than 1⁄4 inch;

• has no tears or loose threads. (An infant or toddler can strangle if his or her head gets caught

in tears in the mesh); 

• Is attached securely to the top rails and floor plate.

No rivets protrude 1/16-inch or more on the outside of the top rails. A toddler can strangle in a play yard or 

portable crib with protruding rivets if a pacifier string or loose (or loosely woven) clothing catches onto one. 

Any staples, rivets, or screws used in construction are not loose or missing.

No mattresses or pads are added that are not provided by the manufacturer.

OTHER RESOURCES: Play Yard Recalls

www.cpsc.gov 19
SMALL PARTS

HAZARDS: Choking, inhaling, swallowing, death. 

Children under 3 years old can choke, inhale, or swallow small parts that 

they put in their mouths. Products intended for children under 3 years old 

are banned if they are, or have, small parts or if one of the components can 

be detached or broken during normal use.

A small part can be any object or a part of an object that fits completely 

into a specially designed test cylinder under its own weight. The picture at 

the right shows the cylinder with a small toy inside. Small part cylinders are 

widely available for purchase.

From 2006 to 2010, the CPSC has reports of 21 children under 3 years of age 

who died from choking, inhaling, or swallowing balloons (8 deaths), small 

balls (8 deaths), and games or parts of toys (5 deaths).

Mandatory

Standards

Recalls

The mandatory standard for small parts went into effect on September 17, 1991. 

Go to: 16 CFR Part 1501. Also see: the Child Safety Protection Act (effective January 1, 1995) 

and 16 CFR Part 1117 (reporting requirements).

Check for recalls involving small parts. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: Destroy products:

• if they have small parts and are intended for children under 3 years old, such as:

— balls with a diameter of 1.75 inches or less;

— dolls and stuffed toys that have eyes, noses, or other small parts that are not fastened securely; 

— preschool toys, games, and puzzles with small parts; 

— nursery products, such as baby bouncers and exercisers with small parts. 

• if they are missing/lack required warning labeling on:

— toys and games intended for children from 3 through 5 years of age. The label must contain a small

parts cautionary statement and safety alert symbol on the packaging;

— balloons intended for children under 8 years old (see Other Resources below);

— products with marbles, small balls, and containing other small parts. The appropriate

labels and instructions can be found in Other Resources below. 

Exceptions to the small parts regulation include: books, modeling clay, crayons, paint sets, and accessories, 

paper products, pencils, and pens. In addition, children’s clothing is exempt from the small parts regulation; 

but be sure that all small buttons and other parts are fastened securely.

OTHER RESOURCES: Business Guidance for Small Parts; Safety Alert — Children’s Balloons; Child Safety 

Protection Fact Sheet

www.cpsc.gov 20

1.25 inches

2.25 inches
TOY CHESTS

HAZARDS: Suffocation, entrapment, strangulation, pinching, 

crushing, or laceration. 

Toy chests with hinged lids that open vertically can collapse or drop suddenly, 

particularly if the lids have a hinge with an adjustable friction lid support (see 

drawing to right). 

The CPSC has received reports of death and brain damage as a result of toy chest 

lids falling onto children’s heads or necks. Most of the children were under 2 

years of age. Accidents occurred when children were reaching over and into the 

toy chest when the lid dropped, either falling onto their heads or trapping them 

at the neck, between the lid and the edge of the toy chest. 

Suffocation deaths have occurred when children climbed into chests to hide 

or sleep. Because the toy chests were not ventilated adequately, the children 

suffocated in the enclosed space. Lid support mechanisms, chest hardware, 

and attachments also have resulted in injuries, such as crushing, pinching, or 

lacerations. 

Mandatory

Standards

Recalls

Toy chests are regulated by the toy safety standard. 

Go to: ASTM Voluntary Standard F963-07e1.

Check www.SaferProducts.gov for toy chest recalls. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: Destroy toy chests that do NOT have:

• a spring-loaded lid support that will keep the lid open in any position without adjustment by the

consumer to ensure adequate lid support; and

• ventilation holes or openings in the front, sides, or a gap under the lid. These ventilation holes should not

be blocked if the chest is placed on the floor against the wall.

Also destroy:

• toy chests with an automatic locking device or a latch. These devices could prevent a child

who climbs into a toy chest from exiting it. 

• non-toy chests with automatic locks, such as trunks, wicker chests, and wooden storage chests

that have been recalled (see recall link below). Children have also died in these chests.

OTHER RESOURCES: Safety Alert — Toy Chests; Toy Chests Recalls

www.cpsc.gov 21

NOT SAFE

Adjustable friction

lid support

USE

Spring-loaded

lid support
TOYS WITH MAGNETS

HAZARDS: Death, intestinal perforation (holes), or blockage. 

Toys containing small, powerful magnets or magnetic components, such as 

construction sets, action figures, dolls, puzzles, and jewelry can kill children if 

two or more magnets are swallowed.

If a child swallows two or more magnets, or swallows a magnet and another 

metal object, such as a small metal ball, the magnetic pieces in different 

areas of the intestines can be attracted to each other through the stomach 

or intestinal walls (see demonstration in picture to right). This will crush the 

trapped internal tissues, cutting off blood flow, and causing serious injury, 

infection, and possibly death. The objects can be removed only with surgery.

Estimates show that thousands of magnet-related ingestions occurred from 

2009-2011. CPSC staff has received numerous reports of magnet-related 

ingestions, many of which required surgical intervention. In many cases the 

magnets had fallen out of larger components of toys or were separated from 

a larger set of magnets (as in the case of “desk toys”). In other cases, children 

swallowed intact toy components containing magnets. Some children 18 months 

to 16 years old required surgery to remove ingested magnets. For prior years, 

CPSC is aware of one death involving a 20-month old child. 

Mandatory

Standards

Recalls

Toys with magnets intended for children up to 14 years old are regulated by the 

toy safety standard (ASTM F963). Go to: ASTM Voluntary Standard F963. 

Check www.SaferProducts.gov for magnetic toy recalls. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: Destroy toys with magnetic parts that:

• have loose or missing magnetic components; or

• have been recalled.

The regulation does not apply to:

• Hobby, craft, and science kits with small magnets and that are intended for children over 8 years if the 

kits are labeled with this warning: “This product contains (a) small magnet(s). Swallowed magnets can 

stick together across intestines causing serious infections and death. Seek immediate medical attention 

if magnet(s) are swallowed or inhaled.”

• Magnets used in devices, where the magnetic properties are not part of the play pattern of the toy, 

such as motors, relays, speakers, and electrical components.

OTHER RESOURCES: Magnets Information Center; Safety Alert — Magnets; Magnets Poster; Button Batteries 

Poster

www.cpsc.gov 22

Demonstration of 

Hazard
BABY WALKERS

HAZARDS: Death, skull fractures, concussions, internal injuries, 

broken bones, cuts, bruises. 

Infant walkers are products that support very young children before they are walking 

(usually 6 to 15 months old). Children may use walkers to sit, recline, bounce, jump, and, 

most importantly, use their feet to move around. Young children can be seriously injured 

or killed if a walker they are in falls down stairs. 

Walkers are now required to have stair fall protection so that a walker either stops at 

the edge of a step or is too wide to fit through a standard size doorway. In 1992, an 

estimated 25,700 children younger than 15 months of age were treated in hospital 

emergency rooms for injuries associated with baby walkers, most from falls down stairs. 

During the period 2004 to 2008, injuries associated with baby walkers decreased by more than 88 percent to 3,000 

injuries annually. It is likely that many of the remaining injuries would be prevented if all walkers met the stair fall 

protection requirement of the mandatory standard. 

Mandatory

Standards

Recalls

The mandatory standard for baby walkers went into effect on December 21, 2010. Before 

that date, a voluntary standard for baby walkers was in effect. Go to: 16 CFR Part 1216.

Check www.SaferProducts.gov for baby walker recalls. It is illegal to sell a recalled product.

RESELLER RESPONSIBILITY: Destroy baby walkers that do not meet 

the CPSC’s mandatory standard that helps prevent falls downstairs. The baby 

walker must have:

• Rubber-like gripping strips underneath, or around the base, to grip the 

floor (see drawing to right); 

• OR, if there are no gripping strips, it must have a base that is at least 

36 inches wide to prevent the baby walker from fitting through a

standard doorway.

OTHER RESOURCES: Business Guidance for Baby Walkers; Baby Walker Recalls

www.cpsc.gov 23

Look for a gripping mechanism 

under the edge of the base.

Too wide to fit through 

doorway

+36 inches
CPSC RESOURCES

CPSC’s Home Page: www.cpsc.gov

Resale Information: www.cpsc.gov/resale

Recalls (CPSC only): www.SaferProducts.gov

Guidance for Resellers Email: Business@cpsc.gov

Business Education: www.cpsc.gov/BusinessEducation

Guidance on the CPSIA 

for Small Businesses: www.cpsc.gov/cpsia

Small Business Information: www.cpsc.gov/smallbiz

Report an Unsafe Product: www.SaferProducts.gov

Regulations, Laws, and 

Information by Product: www.cpsc.gov/table

Enforcement Email: sect15@cpsc.gov

Phone: 301-504-7520

www.cpsc.gov 24

Publication #254, 012013 RV 052014

U.S. Consumer Product Safety Commission

4330 East West Highway, Bethesda, MD 20814