Limited review of the baby bath aids mandatory safety standard
Background information
This page provides background information about the questions in this survey. You can save your answers and come back to this page at any time when completing this survey.
About the baby bath aids mandatory standard
The mandatory standard for baby bath aids was first introduced in 2005 to address the drowning deaths of infants while using baby bath aids in Australia. It covers requirements for warning statement labelling and the testing of these warning labels to ensure permanency.
The mandatory standard was last updated in 2017 and references the 2013 version of the voluntary US standard for infant bath seats (ASTM F1967) subclauses 7.3.1, 7.3.3, and 7.3.4. This voluntary US standard was last updated in 2024, but this update did not make any changes to the subclauses currently referenced in the mandatory standard.
Find out more about the mandatory standard on the ACCC Product Safety website.
Consultation issues
Retain the current mandatory safety standard (maintain the status quo)
If the status quo is maintained, there would be no change to the mandatory standard, and it would continue to reference ASTM F1967-13 subclauses 7.3.1, 7.3.3 and 7.3.4. This voluntary standard has been superseded. Suppliers would be required to test to and ensure the products they supply continue to comply with the current mandatory standard requirements which reference ASTM F1967-13.
Maintaining the status quo would mean that the mandatory standard would not reference other voluntary Australian and overseas standards as compliance options. Businesses will continue to incur additional regulatory and testing costs, and they will not be able to supply products that comply with updated voluntary standards, unless these products are also tested to the particular voluntary standard referenced in the mandatory standard.
Accepting other voluntary standards as compliance options
We have identified voluntary overseas standards that may provide an equivalent level of safety to the mandatory standard. We consider that these could be listed as compliance options in the mandatory standard.
- ASTM F1967-24 - Standard Consumer Safety Specification for Infant Bath Seats — in relation to warning label text and permanency requirements.
- 5.9.1, 7.3.1, 7.3.2, 7.3.3, 7.3.4 – Permanence of warning labels
- 8.4 – Warning Design for Product
- 8.5 – Warning statements to be addressed
- 8.6 – Warning Design for Package
- EN 17022:2018 - Child care articles - Bathing aids - Safety requirements and test methods — in relation to warning label text and permanency requirements.
- 8.2 – Marking of the product
- 8.4 – Instructions for use
- EN 17072:2018 - Child care articles - Bath tubs, stands and non-standalone bathing aids - Safety requirements and test methods — in relation to warning label text and permanency requirements.
- 8.2 – Marking of the product
- 8.4 – Instructions for use
Where a mandatory standard allows for more than one voluntary standard as a compliance option, suppliers can be required by the mandatory standard to include information on which compliance option(s) the product complies with. This compliance information could be marked on the product itself, the packaging or in information provided with the product.
Allowing mandatory standards to be dynamic
Mandatory standards can reference one or more voluntary standards. Voluntary standards are updated from time-to-time. Ordinarily, a mandatory standard would reference only the version of the voluntary standard that was in place when the reference was introduced into the mandatory standard.
Dynamic referencing means that the mandatory standard references a voluntary standard as it exists from time-to-time. This will allow updates to the referenced voluntary standard to flow through to the mandatory standard, keeping pace with global product safety developments.
We propose allowing a 6-month review period before any updates to a referenced voluntary standard take effect in the mandatory standard. During this time, we will review these updates to ensure they are appropriate.
We can recommend to the Minister to stop an update to a voluntary standard taking effect in the mandatory standard, where necessary.
Transition periods
Appropriate transition periods in the mandatory standard allow for:
- changes arising from this review to take effect
- superseded versions of the referenced standards remaining as compliance options for a specified time.
Transition periods allow businesses to:
- sell existing stock
- make manufacturing and design changes
- undertake testing to ensure compliance with an updated standard.