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SPEAC

Safe non-food consumer Products in the EU and China

Wheeled chair conveyances (pushchairs, strollers, and prams)

Wheeled chair conveyances (pushchairs, strollers, and prams)

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Product definition

This factsheet applies to pushchairs and prams. Pushchairs, also known as strollers, and prams are those products designed for the carriage of one or more children, up to 15 kg each and up to 20 kg for any integrated platform on which a child can stand.

This factsheet does not cover toys, baby carriers fitted with wheels; pushchairs and prams propelled by a motor and pushchairs and prams designed for children with special needs.

Common risks of wheeled chair conveyances

This is a list of examples of common risks. However, the manufacturer has to carry out an assessment of the product that covers all relevant risks that may be associated with it and actions taken to mitigate these where possible. A general definition of risk and its relationship to hazards can be found in the factsheet on Risk management.

1. Mechanical/physical risks:

  • Lack of strength, durability or structure resulting in a fall
  • Small parts can cause choking in children under the age of 36 months.
  • Long cords can cause strangulation if they exceed the permitted length.
  • Sharp edges and points can cause cuts, bruising and other injuries.
  • Gaps can cause an entrapment hazard for a child.

2. Chemical risks:

  • Dangerous chemicals can cause short- and long- term adverse health effects if they exceed allowed limits.

3. Thermal risks:

  • Flammable materials can ignite quickly leading to burns.

4. Hygiene risks:

  • Microbiological or other contamination of materials from which the product is made can cause irritation and infections.

A general definition of risk and its relationship to hazards can be found in the factsheet on Risk management

Examples of dangerous products

Specific examples of measures taken against dangerous wheeled child conveyances offered for sale in the European Union are available on the Safety Gate website. Type ‘pram’, ‘pushchair’ or similar expression into the free text search box (but without the quotation marks) and select the ‘Childcare articles and children’s equipment’ Product Category to view notified examples. A better understanding of mistakes made in the safety assessment of the wheeled child conveyance, or its manufacture can help avoid their repetition.

Main applicable legislation

Please note that every product must be safe for consumers, according to the General Product Safety Directive (GPSD) of the EU. This is the applicable law covering wheeled child conveyances.

Under the Directive, a product is safe if it meets all legal safety requirements under European or national law.

A ‘safe product’ shall mean –
any product which, under normal or reasonably foreseeable conditions of use, does not present any risk or only the minimum risks compatible with the product’s use, considered to be acceptable and consistent with a high level of protection for the safety and health of persons

It is important to take into account the following points in particular:

  1. the characteristics of the product, including its composition, packaging, instructions for assembly
  2. the effect on other products, where it is reasonably foreseeable that it will be used with other products
  3. the presentation of the product, the labelling, any warnings and instructions for its use and disposal and any other indication or information regarding the product
  4. the categories of consumers at risk when using the product, in particular children and the elderly
Does your wheeled chair conveyance also have play value?

It is essential for manufacturers to consider whether their products might also have a ‘play value’ to a child, e.g. because it has a rattle effect or some other toy or play item attached to it (i.e. a plush toys attached to the strap). This is because products which have play value are considered as toys and must comply with all the requirements of the Toy Safety Directive 2009/48/EC. To be considered as a toy for the purpose of the Directive, the play value has to be introduced in an intended way by the manufacturer. The EU has issued a good deal of guidance on toy safety to help manufacturers, and this includes guidance document no. 4 which can be found here will specifically help manufacturers consider the issue of childcare articles which may also fall within the definition of being a toy.
Comprehensive factsheets on the requirements concerning toys can be found here.

Does your wheeled chair conveyance also have play value?

Applicable standards

“European standards” exist in the EU for some childcare products, that have been published in the Official Journal of the European Union (OJEU). A product complying with these standards is presumed to meet the EU safety requirements. Further information on, and the list of standards for childcare articles is available from here.

[Note: European standard published in the official Journal of the European Union is called “harmonised standard” when it is adopted on the basis of Union harmonisation legislation. When a EN standard is published in the OJEU under the GPSD, that is a general Directive (non-harmonisation legislation), it cannot be called harmonised standard. In general, EN standards published in the OJEU give the legal effect of presumption of conformity to the products complying with these.]

The main standard for pushchairs and prams EN 1888-1:2018 is not published in the OJEU. It references part of EN 71, the toy standard which is harmonised (refer to EN1888-1:2018 for more information).

The following standard specifically applies to pushchairs and prams:

EN 1888-1:2018 Pushchairs and prams

The standard specifies detailed testing requirements covering all areas of a pushchair and pram which should be followed. The standard covers other safety issues and manufacturers are strongly advised to consult the whole standard and consider any other possible hazards and requirements that affect their product.

Note: The full text of European standards can only be purchased from a national standardisation body. The following site of CEN (the European standardisation organisation) provides links to the national standardisations bodies’ websites. In addition, the China Standards Information Services Network can be used to access European standards.

Other legislation of relevance:

The following summarises some further key applicable laws:

  • REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) – restricts chemical substances in goods. REACH places responsibility on the industry to manage the risks from chemicals and to provide safety information on the substances. Manufacturers and importers are required to gather information on the properties of their chemical substances, which will allow their safe handling, and to register the information in a central database.
  • CLP Regulation (Classification, labelling and packaging of substances and mixtures) – This Regulation requires manufacturers to classify, label and package their hazardous chemicals appropriately before placing them on the market.

Mandatory labelling & warnings

All product information must be given in the official language(s) of the country in which the wheeled child conveyance is sold.

Other important applicable issues

To ensure safety of wheeled child conveyances, there is also a range of general requirements to be fulfilled. These are explained in the following factsheets and need to be read in conjunction with this factsheet:

You may also visit the SPEAC ACADEMY to learn more about the EU Safety requirements.

Disclaimer

The provided information was updated in 2022. Please note that some of the provided information could change during possible subsequent revisions of legislation, standards, and guidance documents. For any updates of official information on the EU product safety rules, please follow the Link to the webpage of the European Commission.

This document was produced with the financial support of the European Union. Its contents are the sole responsibility of SPEAC project and do not necessarily reflect the views of the European Union.