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Clothing Storage Unit Compliance – A Sturdy Act 2023 Update

Clothing Storage Unit with little girl

Over the last 18 months, HFA has engaged with industry, congressional, consumer safety, parents, and regulatory stakeholders to advocate for a consensus-driven mandatory stability standard for clothing storage units (CSU). Clothing storage unit compliance efforts culminated in the passage of the STURDY Act (Stop Tip-overs of Unstable, Risky Dressers on Youth) which was signed into law on December 29, 2022).

As mandated by the new law, the CPSC published a Direct Final Rule on May 4, 2023, in the Federal Register which follows the STURDY Act language to adopt *ASTM F 2057-23 as the federal stability standard moving forward.

In order to ensure you have all the information you need to be familiar with, and comply with, the new law we have outlined key procedural points and requirements of the standard.

All clothing storage units (within the scope defined below) manufactured after September 2, 2023, are subject to the requirements of this regulation.

 

Definitions

ASTM F 2057–23 applies to ‘‘freestanding clothing storage units, including but not limited to chests, chests of drawers, drawer chests, armoires, [chifforobes], bureaus, door chests, and dressers, which are:

  • 27 in. (686 mm) or greater in height
  • 30 lb. (13.6 kg) or greater in mass
  • Contain 3.2 ft3 (90.6 dm3) or greater of enclosed storage volume.

The standard ‘‘does not cover shelving units, such as bookcases or entertainment furniture, office furniture, dining room furniture, jewelry armoires, under-bed drawer storage units, occasional/accent furniture not intended for bedroom use, laundry storage/sorting units, or built-in units intended to be permanently attached to the building, nor does it cover ‘Clothing Storage Chests.’

Testing

ASTM F 2057-23 Stability Tests

  1. The first stability test, Section 9.2.1, Simulated Clothing Load, loads drawers with simulated clothing loads. The clothing storage unit must not tip over with all doors and extendible elements (movable loadbearing storage components including, but not limited to, drawers and pullout shelves) open. This stability test simulates drawers containing reasonable clothing loads in a CSU.
  2. The second stability test, Section 9.2.2, Simulated Horizontal Dynamic Force, applies a 10-pound horizontal force over a period of at least 5 seconds at a ‘‘handhold’’ not to exceed a 56-inch height, and then holds the force for at least 10 seconds. This stability test simulates the pull force of children up to 72 months.
  3. The third stability test, Section 9.2.3, Simulating a Reaction on Carpet with Child Weight, uses 60 pounds of weight placed on the edge of an open drawer or pull-out shelf, while the CSU is tilted forward using a 0.43 inch test block to simulate placement on a carpeted surface, with all doors and extendible elements open. This simulates the static weight of children up to 72 months.

Labeling Requirements

ASTM F 2057-23 relies mainly on warning labels from the previous standard, ASTM F 2057-19, which requires clothing storage units to be permanently marked in a conspicuous location with warnings that meet specified content and formatting.

The warning statements address the risk of children dying from furniture tip-overs; not allowing children to stand, climb, or hang on clothing storage units; not opening more than one drawer at a time; placing the heaviest items in the bottom drawer; and installing tip restraints.

For CSUs that are not intended to hold a television, this is also addressed in the warning.

Additionally, units with interlock systems must include a warning not to defeat or remove the interlock system.

ASTM F 2057-23 DOES NOT require a hangtag.

Current Inventory

It is important to note that retailers can sell clothing storage units made before September 2, 2023, as the standard is prospective and based on manufacture date. There are no sell-through or anti-stockpiling provisions in the regulation.

In other words, your existing stock of CSUs can still be sold after September 2nd.

Next Steps

Now that our industry has certainty on this clothing storage unit safety standard moving forward, furniture retailers MUST engage in a conversation with their manufacturers and vendors to ensure that compliance with this mandatory standard is on track for any clothing storage units manufactured after September 2, 2023. One option for retailers is to ask for a Letter of Intent (LOI) or other similar document to confirm the manufacturer is going to comply with the effective date.

 

Final Note

CPSC Final Rule

The STURDY Act provides that adoption of the ASTM standard will supersede CPSC’s current rule, which was published on November 25, 2022. The CPSC Final Rule, which HFA and others strongly fought against, that was intended to take effect on May 24th is now stayed and will not take effect.

HFA will continue working with its members and other stakeholders to address any issues that arise as this process continues to develop.

 

*ASTM – American Society for Testing and Materials or ASTM International an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials, products, systems, and services

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