1. Children’s Upper Outerwear with Drawstrings

Definitions

• Neck area: means the area one inch above and below the seam between the body

of a garment and the collar or hood.

• Upper outerwear: means clothing, such as jackets and sweatshirts, which is

generally intended to be worn over other garments.

• Child’s Outer Garment: An outer garment (raincoat, overcoat, anorak or other

outer garment for use as outer wear) having a measurement not exceeding 44 cm

(17.32 in.) across the chest when the finished garment is laid out as flat as

possible without distorting its natural two-dimensional shape and buttoned or

otherwise fastened as it is designed to be in normal wear.

• Drawstring: Cord, chain, ribbon, string or tape of any textile or non-textile

material that passes through a channel, loop(s) or eyelets(s) or similar, to adjust

the size of the opening, or part of the garment or to fasten the |garment itself. The

ASTM definition specifies that a drawstring is a non-retractable cord. The

drawstrings usually pull the clothing tight to prevent air and/or water (rain or

snow) seepage. The tightening systems (non-exhaustive list) can be found on the

following garment parts,

Upper neck hem

Hood hem

Jacket or trouser waist-tightener

Trouser or leg gaiter

Glove wrist tightener, etc

Different kinds of hoods and collars may require more drawstrings and locks.

• Decorative Cord: Cord, chain, ribbon, string or tape of any textile or non-textile

material with or without embellishment, such as toggle, pom-pom, feather or

bead, of fixed length and not intended to be used to adjust the size of the opening

or to fasten the garment itself.

• Functional Cord: Cord, chain, ribbon, string or tape of any textile or non-textile

material with or without embellishment, such as toggle, pom-pom, feather or

bead, of fixed length, which is used to adjust the size of the opening, or part of the

garment or to fasten the garment itself.

• Hood: A loose, pliable covering for the head, either detachable or permanently

attached to upper outerwear.

• Loop: Cord or narrow strip of fabric curved in shape, which may be fixed or

adjustable in length, where both ends are attached to the garment.

• Sash: Drawstring, decorative or functional cord of textile material of not less than

30 mm (~1¼ inch) in width worn around the waist of a garment and tied into a

bow.

• Toggle: Wooden, plastic, metal or otherwise composed piece attached to, or

present on, a drawstring for decorative purposes or to prevent the drawstring from

being drawn through its channel.

Introduction –

Drawstrings on children’s apparel can be hazardous and have led to deaths and injuries.

Therefore several countries have taken measures through standards or safety advisories to

reduce the risk of marketing and sale of garments with drawstrings that can be hazardous

or even fatal to children. However, many retailers and manufacturers sell apparel in

multiple countries and variations in drawstring requirements among various countries can

be confusing. One set of requirements that cover their needs for selling in the United

States (US), Canada and European Union (EU) would be ideal. Drawstrings on children’s

apparel can be hazardous and have led to deaths and injuries. Drawstrings can catch on

playground equipment, cribs, bus doors, etc. and potentially strangle a child. Therefore

Canada, the United States and the European Union have all issued standards or guidelines

to minimize the risk of accidental entrapment by drawstrings or cords.

Death and Injuries that can be caused by Children’s Upper

Outerwear with Drawstrings

Waist drawstrings can become Hood and neck drawstrings can become

entangled in a bus door entangled on playground equipment,

cribs, and other common items.

Managing loops/cords by cutting

it short and separating them

Country: United States of America

(USA)

Guidelines for Drawstrings on Children’s Upper Outerwear

The U.S. Consumer Product Safety Commission (CPSC) is an independent federal

regulatory agency that was created in 1972 by Congress in the Consumer Product Safety

Act. The CPSC issued a voluntary guideline (“US Consumer Product Safety Commission

Guidelines for Drawstrings on Children’s Outerwear”) and ASTM issued a standard

(ASTM F1816-97, “Standard Safety Specification for Drawstrings on Children’s Upper

Outerwear”) in 1997.

• In addition to the CPSC/ASTM guidelines, the states of New York and Wisconsin

have implemented mandatory laws. Wisconsin’s standard applies to a broader

range of sizes (0-16) than the CPSC/ASTM and New York (2T-12). Additionally,

the New York requirements for waist and bottom drawstrings apply to all

children’s clothing, as opposed to only children’s upper outerwear for

CPSC/ASTM and Wisconsin.

• CPSC recommends that parents or caregivers completely remove the hood and

neck drawstrings from all children’s upper outerwear, including jackets and

sweatshirts, sized 2T to 12.

• CPSC recommends that consumers purchase children’s upper outerwear that has

alternative closures, such as snaps, buttons, Velcro, and elastic.

\ Canada

Canada’s advisory notice (“Potential Strangulation from Drawstring’s on Children’s

Outerwear”) mirrors the ASTM standard (ASTM F1816-97).

When selling apparel in throughout the US and Canada

Canada has adopted ASTM F1816-97. However, Wisconsin’s drawstring requirements

are more stringent than that of the CPSC/ASTM and New York in most areas. Most

notably, Wisconsin’s requirements apply to a wider size range (0-16). However, New

York’s requirements for the waist or bottom apply to all children’s clothing (not just

children’s upper outerwear as in the PSC/ASTM and Wisconsin requirements).

Therefore, it is recommended that a combination to include the most stringent of

requirements be followed, as below:

Country: European Nations (EN)

In France, investigations have shown that garment drawstrings can cause two types of

accidents, i.e.,

• The strangulation of young children when a drawstring is caught in community

equipment (playgrounds)

• Eye injuries or dental fractures to secondary school children when their hanging,

elastic, hard-tipped drawstrings on their hoods are pulled

The European Commission instituted a standard (EN 14682: 2004, “Safety of Children’s

Clothing ― Cords and Drawstrings on Children’s Clothing-Specifications”) which limits

the use of drawstrings in children’s apparel. This standard was adopted as a national

standard by member states in June 2005.

• The standard was published in the Official Journal of the European Union (OJEU)

2006/C171/04 of 22 July 2006. As a result, clothing in compliance with the safety

requirements prescribed by this standard are now presumed to be in compliance

with the general safety requirement of the General Product Safety Directive

(GPSD), 2001/95/EC of the European Parliament and of the Council of 3

December 2001 on general product safety.

• Publication in the OJEU, does not make it a legal requirement that clothing must

comply. However, the General Product Safety Directive is a legal requirement

implemented in European countries and having articles that comply with

harmonized standards such as EN 14682 is a way of demonstrating that the

product is safe for aspects covered by the standard.

Therefore, if a product does not comply with EN 14682, the seller could be prosecuted

for not complying with the requirements of GPSD as this would be considered to be a

relevant standard. In other words, if a product does not comply with EN 14682, the seller

cannot be prosecuted for noncompliance to EN 14682 per se but could be prosecuted for

not complying with the requirements of GPSD as this would be considered to be a

relevant standard and requirements of EN 14682 is a means to ensure a safe product.

Country: United Kingdom (UK)

In Great Britain, the SI 1976 No. 2 regulation on children’s clothing (hood drawstrings)

bans drawstrings in the fabric hem of the hoods on garments where chest size is smaller

than 44 centimeters. The British 1997 standard BS 1907 referring to this regulation,

• Forbids drawstrings or decorative ribbons longer than 14 centimeters on clothing

for children under 3, and prohibits hard buckle tips longer than 5 centimeters.

Apparel must not have strings – either decorative items or drawstrings - hanging

out of garment back.

• Sets down exact string measurements according to location of the drawstring on a

garment. Drawstrings cannot exceed 14 centimeters at the waist when the garment

is fully loosened. Bottom-half drawstrings cannot be longer than 8 centimeters.

• Recommends spring clips and wide vents. The standard forbids the use of any

aglet likely to increase entrapment (knots or duffel-coat toggle-fastenings, for

instance). Standard neck fastenings like the ones adults wear are not appropriate

for children under 5. The fastenings must be easily detachable in case of

entrapment. Neck fastenings must be removable (hence the recommendation for

Velcro or snap fastenings).

• Specifies that nightwear for children under 3 should not have hoods because they

obstruct the child’s line of view and hearing. Clothing with hoods must be

designed to avoid said inconveniences. Hoods should preferably come off at the

slightest pressure.

• Hood Cords for Children’s Clothing, SI 1976 No. 40 of Ireland is very similar to

UK regulations. Therefore, products distributed in the UK/Ireland must comply

with this requirement in addition to the requirements of EN 14682.

Country: Finland

Finland has no regulations. However on November 18, 1998, the National Consumer

Association (NCA) issued a press release calling for a ban on the import of children’s

apparel with drawstrings around the neck. Several children suffered near suffocation due

to drawstrings.

The NCA drew on the example of Great Britain and, in agreement with Finnish

manufacturers, called for safer children’s apparel by pointing to the fact that Finnish

suppliers were already selling articles with other fastenings (Velcro, elastic bands, and so

on) for older children. Some day-care centers have already acted on this and asked

parents to cut off the drawstring on very young children’s garments. Manufacturers seem

to be aware of the hazards and have designed the appropriate clothing.

Regulations when selling in throughout the US, Canada and the EU

Certain parts of the EU requirements are more stringent than the US/Wisconsin/NY

requirements:

• All size ranges (ages up to 14) are regulated.

• Drawstrings hanging below the hip, cannot hang below the lower edge of the garment.

• Drawstrings cannot protrude from the bottom hem of coats, trousers or skirts that are

designed to finish at the ankle.

• The standard also specifies drawstring requirements for sleeves and other parts of the

garment.

• For hood and neck areas, EU standard covers all ages up to 14 years whereas US

requirements covers up to 12 years. (Note: Age is used as an approximation as the

measurement guidelines represent a retailer's average customer. In the smaller sizes (up

to size 8), the size translates to approximate age.For US sizing, size 10/12 is generally for

ages 9-10, 14/16 is generally ages 11-12 and size 18 is generally 13-14 years. However,

certain portions of the US (including New York and Wisconsin) requirements are more

stringent:

• Only 3 inches of the drawstring are allowed to extend outside the drawstring channel, as

opposed to 5.5 inches (140 mm) for the EU in the waist area.

• For hood and neck areas, the EU allows loop drawstrings for ages 7-14 whereas US

does not allow any drawstring for sizes 2T-12-CPSC/NY (approximate age 10) and 0-16-

WI (approximate age 12).

However, the UK national legislation does not allow drawstrings and cords (ties) for

hood and neck areas in children’s outer wear with chest measurement not exceeding 44

cm (approximately up to 13 years of age).

Therefore, it is recommended to follow one separate specification for US/Canada and

one for the EU. Drawstrings specifications for children’s apparel are specified in the

following two (2) charts.

A research report published in November 1999 entitled "Choking Risks to

Children" evaluated the effectiveness of the ‘small parts cylinder’ test in

preventing choking accidents to children under four from small toys or parts

Garments.

The Garment should not have any accessories exceeding the size mentioned

below.

AUSTRALIA AND NEW ZEALANDCHOKING HAZARD – INHALATION AND INGESTION.

This is a hazard caused by a component or failure of a component, which if

inhaled or ingested by a child can create an obstruction in the airway, or

poses a risk of perforation in the esophagus.

Toy Standard AS/NZS ISO 8124.1:2002)

Small Parts

• Small parts include non-porous material smaller than 3cm diameter.

• Small parts must be secure and not able to be removed from the garment.

Known Examples:

• Buttons, studs, eyelets, toggles.

• Trims – beads / sequins / pompoms / animal eyes or noses.

• Buckles / zip pullers.

• Battery case for sound box.

• Filling in toys.

• Decorative motifs, eg: butterflies; flowers.

. TOGGLES

_ Must securely attached

_ Must pass bite test (as per AS1647.2).

_ Prohibited around neck area (3 yrs and under).

_ Cord must be securely attached at both ends preventing toggle from falling

off or pulled off.

TRIMS

ZIPS

Glass prohibited

Zip pull to pass bite test (as per AS1647.2)

Plastic zips are recommended for age 3 years and under, unless harsh wash

item.

Zips must be Burr free

Nylon Zip not to have excess teeth beyond top stop

FASTENERS

Ties to be kept to a minimum length, to be fit for purpose, eg: enough

length to tie a bow, if relevant to product.

Ribbon ends to be heat-sealed or bar tacked.

Rope to be securely knotted at ends.

Mock ties preferred in lieu of draw cord.

Ties in hood & hat to be secured – Prohibited for newborn.

Chin ties to be open-ended (not looped).

Elastic relaxed measurement to meet minimum size requirements to

prevent lack of circulation.

Soft quality elastic preferred for newborn and sleepwear.

Binding ends to be knotted or bar tacked.

Elastic Cord to be secured at opening – to be non-functional, loop to be no

more than 2.5cm

Non-stretch cord preferred

� Velcro to be positioned to avoid contact with skin, Corners to be rounded,

Use soft quality Velcro

FLOATING / LOOSE THREADS:

Goods contain no floating threads in the toe or finger area for infants up to

12 months of age.

The goods contain no loose and or floating threads longer than 1cm on the

inside or outside of the remaining article for infants up to 18 months and

2.5cm over 18 months.

Terry toweling: Looped yarn to break at 3cm when pulled by hand – not to

be able to be continuously pulled to form a loop.

Loose or Untrimmed Threads in Feet, Hands or Crotch : PROHIBITED

BELTS

Chain Belt Sold with Garment: Prohibited for 3yrs and under.

Prohibited for 3yrs and under : Prohibited for 3yrs and under.

Informal Comparison Between Various U.S. Drawstring Standards

ASTM Standard (F 1816-97)1

Wisconsin Law (ATCP 139) 2 New York (A10866) (Amendment to A01865 from 2002).

How implemented

Voluntary national standard Already implemented.

State regulation. Effective Date: January 1, 2000.

State law. Effective upon enactment.

Neck area prohibitions

No drawstrings in the hood and neck area of certain children’s clothing.

1 • Only children’s upper outerwear.

2 • Sizes 2t to 12.

No drawstrings in the hood and neck area of all children’s clothing.

1 • All children’s clothing.

2 • Sizes 0 to 16.

No drawstrings in the hood and neck opening of certain children’s clothing.

1 • All children’s clothing.

2 • Sizes 0 to 12.

Waist/bottom prohibitions

Drawstrings at waist and bottom of certain children’s clothing subject to limitations.

1 • Only children’s upper outerwear.

2 • Sizes 2t to 16 3 • Drawstrings may

not extend more than 3 inches (75mm) past channel when garment is expanded to fullest width.

4 • No toggles, knots, or other attachments at free ends.

5 • “Bartacked” if drawstring is one continuous string.

Drawstrings at waist and bottom of certain children’s clothing subject to limitations.

1 • Only children’s upper outerwear.

2 • Sizes 0 to 16 3 • Drawstrings may

not extend more than 3 inches past channel when garment is expanded to fullest width.

4 • No toggles, knots, or other attachments at free ends.

5 • Drawstring is sewn to garment at midpoint of channel so it cannot be pulled out of channel.

Drawstrings at waist and bottom of all children’s clothing subject to limitations.

1 • All children’s clothing.

2 • Sizes 2t to 16 3 • Drawstrings may

not extend more than 3 inches past channel when garment is expanded to fullest width.

4 • No toggles, knots, or other attachments at free ends.

• Attached to garment at midpoint of drawstring.

Exemptions Upper outerwear with fully retractable drawstrings.

None. None

Definitions Definitions cover the terms: bartack, bottom of upper outerwear, drawstring, hood, neck area, neck opening, toggle, upper outerwear, and waist.

Definitions cover the terms: neck area, upper outerwear.3 These terms are modeled after ASTM definitions.

Definitions cover the terms: sell at retail, drawstring, tie, hood, neck opening, toggle, and aglet. Note: Ties are not considered drawstrings and aglets are not considered toggles.