The mandatory standard prescribes requirements for the performance testing, design, construction, safety warnings and labels of prams and strollers.
A pram is a wheeled vehicle with a body of box-like or boat-like shape designed to carry a baby or child weighing up to and including 9 kg, primarily in a fully reclined position.
A stroller is a wheeled vehicle designed to transport a child in a seated position that may also be adjusted to a semi-reclined or fully reclined position.
There are also combination prams/strollers on the market. These can seat children in upright, semi reclined and fully reclined positions. These are considered strollers under the mandatory standard.
Strollers and chairs designed for children with disabilities, which are medical devices regulated by the Therapeutic Goods Administration (TGA), are not intended to be captured by the mandatory standard.
The ACCC revised the mandatory standard for prams and strollers through the addition of an explanatory note. The amendment to the Consumer Product Safety Standard for Prams and Strollers - Consumer Protection Notice No. 8 of 2007 commenced on 14 February 2019. Suppliers of convertible products are responsible for ensuring the products they supply meet the requirements of the mandatory standard.
The note states that where a product is a convertible product and that product has a mode designed to transport a child in a seated position, it is a stroller for the purpose of the safety standard. These products must meet the requirements of the mandatory standard. Products of this type may include convertible tricycles and other wheeled vehicles.
Convertible tricycles are not a homogenous product category (that is, not all tricycles are the same). Suppliers need to make their own assessments of individual devices against the mandatory standard.
Convertible tricycles designed for children younger than 24 months
Convertible tricycles are more likely to be considered strollers for the purposes of the mandatory safety standard if they are designed for children younger than 24 months and include some combination of one or more of the below key features, which are not typically found in traditional tricycles. Key features include:
- a high backrest for the child
- a harness for the child
- ability to disengage child steering
- ability to disengage or remove the pedals
- ability to semi-recline or recline the child’s seat.
Children under 24 months are unlikely to be able to independently operate a tricycle. This is supported by the US CPSC Age Determination Guidelines, which have been referenced in the AS/NZS toy standard and are used by Australian product safety regulators to assist our work. The latest version of the Guidelines are available on the US CPSC website. The guidelines state that children under 24 months do not have the motor skills necessary to steer or pedal even with parental assistance.
Convertible tricycles with lowest age modes of 12 months and under
The ACCC is particularly concerned about convertible tricycles with lowest age modes of 12 months and under. There have been a number of voluntary recalls for these devices. We do not consider it is in any way possible for children in this age category to operate these devices as tricycles.
You must consult Consumer Product Safety Standard for Prams and Strollers - Consumer Protection Notice No. 8 of 2007 which sets out the mandatory requirements for prams and strollers.
The mandatory standard is based on the voluntary Australian New Zealand Standard AS/NZS 2088:2000 'Prams and strollers—safety requirements'. AS/NZS 2088:2000 is available from SAI Global.
These requirements aim to provide an overview of the mandatory standard. Suppliers must not rely on this information as a complete guide to compliance.
Note that there are additional requirements for strollers that do not apply to prams.
Design and construction—prams and strollers
Prams and strollers must have one or more parking devices that limits the movement of the pram or stroller.
The release mechanism of the parking device must be located so that it is not easily accessible to a child when the child is properly restrained in the pram or stroller.
The colour of the part of the parking device used to activate the parking mechanism (actuator) must be red, and surrounding framework and mouldings must be a contrasting colour.
Prams and strollers must be supplied with a suitable tether strap that allows the operator of the pram or stroller to be tethered to it while it is in use.
The standard specifies that the tether strap should be designed to reduce the possibility of it being a strangulation hazard for infants inside or outside the vehicle. The length of the strap should be as short as is practical, with any loop in the strap having a perimeter of less than 360 mm.
The mandatory standard specifies testing to ensure prams and strollers meet requirements for impact, strength, load, durability and stability. Suppliers need to organise this testing through specialist laboratories.
Strollers have additional performance testing requirements.
Design and construction—strollers only
Strollers must have a permanently attached harness assembly that includes waist and crotch straps for each occupant. Strollers designed for more than one child must meet this requirement for all seating positions.
The adjustable range of each harness should be such that the harness can be adjusted to fit the range of occupants for whom the vehicle is designed.
Waist straps must have a minimum width of 20 mm. Waist straps and fittings for waist straps must be secured to the frame of a stroller either directly, or to a seat which is attached to the frame of the stroller.
The crotch strap must have a minimum width of 20 mm, be linked to the front waist strap and be located not more than 200 mm from the backrest.
Strollers with a backrest that reclines to an angle greater than 150° to the horizontal when in the fully laid back position must have a barrier provided that does not create a head entrapment hazard when tested in accordance with clause 8.6.2 and appendix L.
Head barrier requirements also apply to strollers with multiple/double seating and reclining positions where the head is at either end of the vehicle.
Safety warnings—prams and strollers
Tether straps must be permanently and conspicuously marked with a warning in characters not less than 2.5 mm high as follows:
WARNING: USE THIS STRAP TO STOP THE PRAM/STROLLER* ROLLING AWAY
(* Use either the term 'pram' or the term 'stroller' as appropriate).
Prams and strollers must be permanently and conspicuously marked with the below notice in a prominent position in characters not less than 2.5 mm high bearing the following:
- FOLLOW THE MANUFACTURER'S INSTRUCTIONS
- PUT ON ALL THE BRAKES WHENEVER YOU PARK THE PRAM/STROLLER*
- DO NOT LEAVE CHILDREN UNATTENDED
- DO NOT CARRY EXTRA CHILDREN OR BAGS ON THIS PRAM/STROLLER*
- MAKE SURE CHILDREN ARE CLEAR OF ANY MOVING PARTS IF YOU ADJUST THE PRAM/STROLLER*, OTHERWISE THEY MAY BE INJURED.
(* Use either the term 'pram' or the term 'stroller' as appropriate).
Safety warnings—strollers only
Stroller harnesses must be permanently and conspicuously marked with the following warning in characters not less than 2.5 mm high:
WARNING: USE THIS HARNESS AT ALL TIMES
If a stroller's backrest is not adjustable to recline to an angle of more than 130° to the horizontal, it must be permanently and conspicuously marked with an additional warning.
The warning should appear in characters not less than 2.5 mm high, as follows:
NOT RECOMMENDED FOR A CHILD UNDER 6 MONTHS OLD
Informative labels—prams and strollers
Prams and strollers must be permanently and conspicuously marked with:
- the registered trade name and address in Australia and New Zealand of either the manufacturer, importer or supplier
- the model name or model number of the pram or stroller.