CPSC Requirements Matrix

CPSC 

Paragrap

h Title Requirement or Test Issues Possible Solutions

1512.1 Scope

Requirements do not apply to "track 

bicycles" or "one-of-a-kind" bicycles.

Track bicycle definition 

does not allow clincher 

tires. Should definition 

include all fixed gear 

bicycles and adopt new 

requirements specific to 

this niche?

1. Modify to include clincher 

tire 2. Consider new "fixed 

gear" definition per other 

comments

1512.2 Definitions

Bicycle; Sidewalk Bicycle; Seat Height; 

Track Bicycle; One-of-a-kind Bicycle; 

Normal Riding Position.

There are now many more 

types of bicycles than when 

this specification was 

written. Should we define 

the large categories and 

adopt regulations and tests 

that are more specific to 

each category?

Suggest ASTM use 

classification. Definitions of 

the various bike types (like 

the CEN classifications) are 

too difficult to agree upon. 

Separate fixed gear bikes vs 

track bikes. Clearly define 

children's bikes.

1512.3 General

Bicycles subject to the regulations shall 

meet the requirements. Bicycles sold 

that require assembly shall meet the 

requirements after assembly.

1. No clarity on bicycles 

sold without pedals 2. 

Bikes are now sold over the 

internet

Options: 1. Leave in 

ambiguity regarding pedals 

(retailer issue) 2. Exclude 

"racing" bicycles 3. Adopt 

standard pedal dimensions 

for pedal-related tests

1512.4 Mechanical Requirements

1512.4a Assembly

Normal intelligent adult shall be able to 

assemble.

1512.4b Sharp Edges No sharp edges or burrs.

Add the following language: 

"accessible during normal 

handling or riding bicycle" 

(From TAG) This would 

exclude items such as 

chainrings.

1512.4c Integrity

No visible fractures resulting from 

testing. 1512.18d, 1512.18e, 1512.18p

1512.4d Attachment Hardware

Screws, bolts & nuts shall not loosen, 

fail or fracture.

1512.4e & fReserved N/A

1512.4g Excluded Area

No protrusions except cables up to 6.4 

mm (1/4 in) and cable clamps made of 

material not thicker than 4.8 mm (3/16 

in) may be attached to the top tube.

Cable stops on TT violate 

this requirement.

Allow protrusions up to 

12mm. 

1512.4h Reserved N/A

1512.4i Control Cable Ends

Protective caps or treated to prevent 

unraveling. 1512.18c. Accessible cable ends only

1512.4j Control Cable Abrasion

Shall not abrade over fixed parts and 

shall enter and exit cable sheaths 

inline. Need diagram for example

1512.5

Requirements for Braking 

Systems

1512.5a Braking system

Shall be equipped with front and rear 

wheel brakes or rear wheel brakes 

only.

Fixed gear bikes on the 

market with no hand 

brakes/one front hand 

brake/two hand brakes

Option 1 Specify bike to be 

equipped with at least one 

independent braking system 

(CEN requires 2). This would 

also apply to rear-only 

coaster brakes. 

Option 2 Define fixed gear 

bike as any other type of bike 

(required to have at least one 

brake)
CPSC Requirements Matrix

1512.5b Handbrakes

Test 10 times by applying a force 

sufficient to cause the lever bar to 

contact the handlebar or 445 N (100 

lbf.) and shall be rocked back and forth 

with 150 lbs on seat and there shall be 

no visible fractures, failures, movement 

of clamps, or misalignment of brake 

components. Test per 1512.18d2, 

1512.18d2iii.

1512.5b1 Stopping Distance

150 lb rider, 15 mph, stop in 15 ft. Test 

per 1512.18d2v & vi. 

1512.5b2 Hand Lever Access

Readily accessible when in a normal 

riding position.

1512.5b3 Grip Dimension

Shall not exceed 89 mm (3 1/2 in) 

between the pivot point and lever 

midpoint and the handlebars - may 

increase toward open end (figure 5).

Some current brake levers do 

not meet this std. Increase to 

100 mm.

1512.5b4 Attachment

Securely attached with locking device, 

lock washer lock nut, etc. and shall not 

loosen during rocking test. Cable 

anchor bolt shall not cut cable strands. 

Test per 1512.18d2iii.

1512.5b5 Operating Force

Less than 44.5 N (10lbf) shall cause 

the brake pads to contact the braking 

surface applied to the hand lever at a 

point 25 mm (1.0 in) from the end of 

the lever.

1512.5b6 Pad & Pad Holders

Pads replaceable and adjustable to 

engage breaking surface without 

contacting tire or spokes, pad holders 

securely attached. Brake pad retained 

during rocking test. Test per 

1512.18d2iii. No disc brake standard

1512.5b7 Reserved N/A

1512.5b8 Hand Lever Location Rear brake right, front brake left. 

Does not account for only 

one hand brake such as on 

some fixed gear bikes, see 

1512.5(a)

Differentiate between track 

bikes and fixed gear bikes. 

When only one brake is 

installed, lever located on the 

right to make it consistent 

with most other nation's 

standards and track bikes 

(CEN defers to national 

standards for placement)

1512.5b9 Hand Lever Extensions Tested like levers.

1512.5c Footbrakes Tested per 1512.18e2

1512.5c1 Footbrake Stopping Distance

150 lb rider, 10 mph, stop in 15 ft. 

1512.18e3.

1512.5c2 Footbrake Operating Force Opposite of drive force

1512.5c3 Crank Differential

Not more than 60° at no less than 

13.6N-m (10 ft-lb) both directions.

1512.5c4 Independent Operation

Shall function independent of any drive 

gear positions or adjustments.

1512.5d

Footbrakes and Handbrakes 

in Combination

Shall meet all requirements of each. 

1512.18e3.

1512..5e1 Sidewalk Bicycles Not handbrakes only.

1512..5e2 Sidewalk Bicycles

If seat height 22 in. or greater at lowest 

adjustment, must have footbrakes. 

1512.18f.

1512..5e3 Sidewalk Bicycles

If seat height 22 in. or greater at lowest 

adjustment with no footbrake must not 

have freewheel. Label required - No 

Brakes. 1512.18f.

1512.6

Requirements for Steering 

Systems
CPSC Requirements Matrix

1512.6a

Handlebar Stem Insertion 

Mark

Permanent mark indicating minimum 

insertion depth. Mark no affect 

structural integrity. Shall not be less 

than 2 1/2 times the stem diameter 

from the lowest point of the stem. Stem 

strength maintained for at least the a 

length of one shaft diameter below the 

mark. Applies only to quill stems

Add threadless stem 

requirements. Adopt 

clamping requirements EN 

14764:2005 (e) 4.7.4. Also, 

max steer tube exposure - no 

more than 40 mm in spacers 

(between top of hdset and 

bottom of stem).

1512.6b Handlebar Stem Strength

Shall withstand a force of 2000 N (450 

lbf) (1000N (225 lbf) for sidewalk 

bicycles). 1512.18g.

1. Not consistent (lower) 

than EN requirements 

2. No differentiation for DH, 

road, ATB etc.

Consider using EN 

requirements

1512.6c Handlebar

Shall allow comfortable and safe 

control. Ends shall be symmetrically 

located in respect to the longitudinal 

axis. No more than 406 mm (16 in) 

above the seat in its lowest position.

Recumbents do not meet 

the standard

Exempt recumbents for the 

regs by definition. Some 

comfort bikes also have this 

issue. Suggest increase to 

500mm.

1512.6d Handlebar Ends

Ends shall be capped or covered. 

Handgrips, end plugs, control shifters 

shall be secure against removal by a 

force no less than 66.8 N (15 lbf). 

1512.18c.

1512.6e Handlebar and Clamps

Assembly instructions must include 

warning about the danger of damaging 

stem-to-fork assembly and the risk of 

injury from over tightening. 1512.18h Applies to quill stems only

Include when creating new 

threadless stem standard

1512.7 Requirements for Pedals

1512.7a Construction

Pedals shall have left-hand/right-hand 

symmetry. Tread surface on top and 

bottom except if one sided.

Clipless pedals do not have 

treads

No tread surface required. 

EN 14764:2005 (e) 4.13.1.3 

1512.7b Toe clips Toe clips to be securely attached.

1512.7c Pedal Reflectors Shall have reflectors. 1512.16e

Clipless pedals and most 

aftermarket BMX pedals do 

not have reflectors

Create exception for clipless 

pedals (aftermarket pedals 

are not required to have 

reflectors). Adding reflector 

"platforms" to clipless pedals 

is not a solution. Continue 

reflector requirement for 

children's bikes and bikes 

sold with non-clipless 

pedals.

1512.8 Requirements for Chain Drive

Shall operate without catching or 

binding. Chain tensile strength no less 

than 8010 N (1800 lbf). (6230 N (1400 

lbf) for sidewalk bicycles).

1512.9

Requirements for Protective 

Guards

1512.9a Chain Guard

Bicycles with a single front sprocket 

and a single rear sprocket shall have a 

chain guard. Shall cover the top strand 

of the chain and at least 90° of the 

perimeter where the chain contacts the 

drive sprocket (figure 7). Rearward 

point at least 8 cm (3.2 in) forward of 

the centerline of the rear axle. Top 

shall be twice the width of the chain 

forward of the rear rim, rear part may 

be tapered to 1/2 the chain width. 

Chain guard shall prevent a rod of 9.4 

mm (3/8 in) diameter and 76 mm (3.0 

in) length from entrapment between the 

upper junction of the chain and the 

sprocket from chain side in any 

direction within 45° from line normal to 

the sprocket.

1. Does it apply to belt 

drives? 2. Consumers do 

not want chainguards 

except on children's bikes

Option 1: Update to allow 

conventional chain guard OR 

chainwheel disc (bash guard) 

similar to EN 14764:2005 (e) 

4.16 Option 2 (preferred) 

Limit full chainguard 

requirement to children's 

bikes, does not apply to 

bikes not intended for 

children (can use bash guard 

style)
CPSC Requirements Matrix

1512.9b Derailleur Guard

Shall be guarded to prevent the chain 

from interfering or stopping the rotation 

of the wheel through improper 

adjustments or damage.

1. Will not fit on modern 

wheel designs or 11-speed 

drivetrains 2. Often 

removed by consumer

Create exception for "racing" 

bicycles.

1512.10 Requirements for Tires

Inflation pressure molded into side of 

tire in letters no less than 3.2 mm (1/8 

in) in height. English using Arabic 

numerals. Tire shall remain intact on 

rim while being tested under a load of 

2000 N (450 lbf) per 1512.18j. Tubular 

exempt. 1512.18j.

Tubular rolloff - should 

there be a requirement for 

tubular tire attachment? No recommendation

1512.11 Requirements for Wheels

1512.11a Spokes No missing spokes.

1512.11b Alignment

Wheel assy shall be aligned such that 

no less than 1.6 mm (1/16 in) 

clearance exists between the tire an 

fork or any frame member when the 

wheel is rotated in any position.

1512.11c Rims

Rims shall retain the spokes and tire 

when side-loaded with 2000 N (450 lbf) 

and tested per 1512.18j. Sidewalk 

bicycles exempt. 1512.18j.

1512.12

Requirements for Wheel 

Hubs

1512.12a Locking Devices

Wheels to frame with a positive locking 

device tightened to manufacturers 

specifications.

1512.12a1Rear Wheels

No relative motion between the axle 

and the frame when a force of 1780 N 

(400lbf) is applied symmetrically to the 

axle for a period of 30 seconds in the 

direction of wheel removal.

1512.12a2Front wheels

Locking devices, except QR, shall 

withstand torque in the direction of 

removal of 17 N-m (12.5 ft-lb). No disc brake QR standard

1512.12b Quick Release Devices

Shall be adjustable for setting 

tightness. Locked and unlocked 

position visible to rider. QR clamp shall 

emboss the frame or fork when locked.

Differs from EN 

requirements

EN standard is confusing and 

hard to test. Need to exclude 

"emboss" for carbon 

dropouts as this can damage 

the dropout.

1512.12c Front Hubs

Positive retention feature when not QR 

tested per 1512.18j3 so wheel will not 

separate from fork. 1512.18j3.

No specific retention tab 

requirement even though 

industry standard

Create retention tab 

requirement or adopt 

relevant EN standard

1512.13 Requirements for Front Fork

Strength tested by 39.5 J (350 in-lb) of 

energy per 1512.18k1 without visible 

indication of fracture. Sidewalk bicycles 

exempt. 1512.18k1.

How do we deal with nonductile materials, i.e. carbon 

fiber? Adopt CEN impact 

testing?

Consider creating standard 

based on fork material and 

intended use. Need 

suspension fork test 

standards. CEN is a good 

starting point.

1512.14

Requirements for Fork and 

Frame Assembly

Strength tested by applying a load of 

890 N (200 lbf) or at least 39.5 J (350 

in-lb) of energy, whichever results in 

the greater force per 1512.18k2 without 

visible evidence of fracture or frame 

deformation that significantly limits the 

steering angle over which the wheel 

can be turned. Sidewalk bicycles 

exempt. 1512.18k2.

Much lower then EN 

requirements, no impact 

test, no carbon fork 

standard

Allow EN requirements as 

alternative

1512.15 Requirements for Seat

1512.15a Seat Limitation

No part of the seat shall be more than 

125 mm (5.0 in) above the top of the 

seat surface at the point where the 

seat surface is intersected by the seat 

post axis.

Recumbents do not meet 

the standard

Exempt recumbents for the 

regs by definition
CPSC Requirements Matrix

1512.15b Seat Post

Permanent mark indicating minimum 

insertion depth. Mark no affect 

structural integrity. Shall not be less 

than 2 times the stem diameter from 

the lowest point of the stem. Stem 

strength maintained for at least the a 

length of one shaft diameter below the 

mark.

Seat mast diameter 

clarification required for 

"racing bikes" and aero 

designs, no "insertion" with 

seat mast design, variety of 

designs

Add requirements for 

bicycles with seat masts and 

define based on cross 

section and minimum 

"overlap" versus insertion 

mark.

1512.15c Adjustment Clamps

Shall be capable so securing the seat 

in any position preventing movement in 

normal use. Following the road test, 

the seat clamps shall be tested per 

1512.181. Follow CEN standard

1512.16

Requirements for 

Reflectors

Shall be equipped with reflective 

devices to permit recognition and 

identification under illumination from 

motor vehicle headlights. Off center 

reflectors acceptable if they meet this 

and 1512.18m & n. The combination of 

reflectors has a clear field of view of +/- 

10° vertically and +/- 50° horizontally. 

Sidewalk bicycles exempt. 1512.18m2, 

1512.18m & n.

1512.16a

Front, Rear, and Pedal 

Reflectors

Colorless front-facing. Colorless or 

amber pedal. Red rear-facing.

1512.16b Side Reflectors

Retroreflective tires or reflectors 

mounted on spokes of each wheel, 76 

mm (3.0 in) from inside of rim visible on 

each side of the wheel

1512.16c Front Reflector

The reflector shall not contact the 

ground when bike is on the ground. 

The optical axis of the reflector shall be 

directed forward within 5° of horizontalvertical alignment when wheels 

tracking straight. Must meet 1512.18m 

test.

Look at the requirements for 

1512.18(m) - reflector mount 

and alignment test. Does not 

address band-style clamps.

1512.16d Rear Reflector

The reflector shall not contact the 

ground when bike is on the ground. 

Mounted to the rear of the seat mast 

with the top of the reflector 76 mm (3.0 

in) below the top of the seat post. The 

optical axis of the reflector shall be 

directed rearward within 5° of 

horizontal-vertical alignment when 

wheels tracking straight. Must meet 

1512.18m test.

Look at the requirements for 

1512.18(m) - reflector mount 

and alignment test. Does not 

address band-style clamps.

1512.16e Pedal Reflectors

Shall be located on front and rear. 

Shall be recessed.

Clipless pedals and most 

aftermarket BMX pedals do 

not have reflectors

Create exception for clipless 

pedals and aftermarket 

pedals. 

1512.16f Side Reflectors

Within the spoke cage not to exceed 

the angle of the spokes. Colorless or 

amber front; colorless or red rear.

Wheels without 

conventional spokes

Revise description of 

attachment methods

1512.16g Reflector Tests

The pedal, front-mount, rear-mount, 

and side mount reflectors must meet 

1512.18n tests. 1512.18n.

1512.16h Retroreflective Tires

When used instead of reflectors, must 

meet the requirements of 1512.16h 1-4 

and 1512.18o2i.

1512.16i Retroreflective Rims

When used instead of reflectors, must 

meet the requirements of 1512.16h 1-

3, 1512.18r and 1512.18o.

1512.17 Other Requirements

1512.17a Road tests Must meet 1512.18p

1512.17b Sidewalk Bicycle Proof Test Must meet 1512.18q
CPSC Requirements Matrix

1512.17c Ground Clearance

Tilt 25° vertical without pedals or any 

other part except tires touching ground.

How far does pedal stick 

out from crank arm? Does 

not account for suspension 

system impact on ground 

clearance

Define standard pedal - EN 

standard is also 25 ° but 

accounts for suspension sag 

EN14764:2005 (e) 4.13.2.1

1512.17d Toe Clearance

If not equipped with positive footretaining devices shall have at least 89 

mm (3 1/2 in) between centerline of 

pedal and front tire or fender (figure 6).

Does not account for very 

small frame sizes

Adopt EN14764:2005 (e) 

4.13.2.2 - standard is 100mm. 

Instruction/warning label for 

bike if intended for use with 

clipless pedals.

1512.18 Tests and Test Procedures

If tests are different from 

CEN tests, double testing 

may be required.

Follow applicable CEN tests 

or accept specified CEN tests 

in lieu of CPSC tests to avoid 

duplicative testing.