Hotel Cribs and Portable Cribs on US Projects: What 16 CFR Parts 1219, 1220 and 1130 Say About Places of Public Accommodation
Which part applies, the ASTM editions, the dates and the marking and registration duties, read from the text of Parts 1219, 1220 and 1130
A US hotel that puts cribs or portable cribs in its guest rooms is not only a buyer of furniture. In the language of the federal crib rules, it is a “place of public accommodation affecting commerce”, and the rules apply to the cribs it offers to guests. If a hotel package from China includes cribs, play yards or similar infant sleep products, three parts of Title 16 of the Code of Federal Regulations decide what the buyer should ask for: Part 1219 for full-size cribs, Part 1220 for non-full-size cribs, and Part 1130 for registration and marking of durable infant or toddler products.
This article reads those three parts as published on the Electronic Code of Federal Regulations, in the full text current to 19 October 2026, the latest issue date for Title 16 when we read it on 24 October 2026. It also reads a one-page CPSC leaflet for hotels and motels. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. It sets out what the text says. We did not read ASTM F1169-25 or ASTM F406-24, the standards the rules adopt, nor the CPSC’s rules on certification and testing of children’s products, penalties, or any state rule. It is not legal advice, and your counsel or compliance adviser confirms what applies to your project.
Which part covers which crib
Parts 1219 and 1220 divide the cribs by interior size. Part 1219 defines a full-size baby crib as a bed within ±5.1 cm (±2 in.) of set interior dimensions, which are 71 ±1.6 cm wide and 133 ±1.6 cm long; Part 1220 starts where Part 1219 stops. Our arithmetic shows the two line up: 133 cm less 5.1 and 1.6 is 126.3 cm and 133 plus 6.7 is 139.7 cm, which are the length limits in Part 1220, and the same sum on 71 cm gives the width limits of 64.3 and 77.7 cm.
| Part 1219: full-size baby cribs | Part 1220: non-full-size baby cribs | |
|---|---|---|
| Bed designed for | Sleeping accommodations for an infant | Sleeping accommodations for an infant |
| Intended for use | In the home, in a child care facility, a family child care home, or a place of public accommodation affecting commerce | In or around the home, for travel, in a child care facility, a family child care home, a place of public accommodation affecting commerce and other purposes |
| Interior size | Within ±5.1 cm (±2 in.) of 71 ±1.6 cm (28 ± 5/8 in.) wide and 133 ±1.6 cm (52 3/8 ± 5/8 in.) long | Interior length greater than 139.7 cm (55 in.) or smaller than 126.3 cm (49 3/4 in.), or interior width greater than 77.7 cm (30 5/8 in.) or smaller than 64.3 cm (25 3/8 in.), or both |
| Named types | — | Portable crib, crib pen, specialty crib, undersize crib, oversize crib |
| Not included | — | Mesh/net/screen cribs, nonrigidly constructed baby cribs, cradles (rocker and pendulum), car beds, baby baskets, bassinets (junior cribs) |
| Standard adopted | ASTM F1169-25, approved December 15, 2025 (section 1219.2) | ASTM F406-24, approved August 1, 2024, with fourteen exclusions of listed sections (section 1220.2) |
The place of public accommodation definition is the same in both parts: “any inn, hotel, or other establishment that provides lodging to transient guests”, except an establishment treated as an apartment building for purposes of any State or local law or regulation, or one located within a building that contains not more than five rooms for rent or hire and that is actually occupied as a residence by the proprietor.
Part 1220 also defines a play yard, a framed enclosure that includes a floor and has mesh or fabric sided panels primarily intended to provide a play or sleeping environment for children, which may fold for storage or travel. The same part excludes bassinets and cradles from the non-full-size crib definition. Part 1130, covered below, still lists bassinets and cradles among the products it regulates, so a product can fall outside Part 1220 and inside Part 1130.
The dates and what they apply to
Both Part 1219 and Part 1220 set the same two dates. Compliance is required on June 28, 2011, and applies to “the manufacture, sale, contract for sale or resale, lease, sublet, offer, provision for use, or other placement in the stream of commerce” of a new or used crib on or after that date.
Paragraph (b)(2) of each part gives child care facilities, family child care homes and places of public accommodation affecting commerce until December 28, 2012. It adds that this provision “applies only to the offer or provision for use of cribs by” those entities “and not the sale, resale, or other placement in the stream of commerce of cribs by these entities”. Our reading of the two paragraphs together: the rule applies from 2011 to the manufacture, sale, lease and other placement of cribs in commerce, and from 2012 to a hotel’s offer of a crib to guests. A crib bought for a hotel today therefore falls within the rules on both counts.
The standards each part adopts
Section 1219.2 requires each full-size baby crib to comply with all applicable provisions of ASTM F1169-25, Standard Consumer Safety Specification for Full-Size Baby Cribs, approved December 15, 2025. The note under the section records an amendment at 91 FR 23913 on May 4, 2026. The edition the rule incorporates is a 2025 one, while the source note for the part dates from 2010, which matters for a buyer holding a test report: the report should name the edition the rule currently incorporates.
Section 1220.2 requires each non-full-size baby crib to comply with ASTM F406-24, Standard Consumer Safety Specification for Non-Full-Size Baby Cribs/Play Yards, approved August 1, 2024, with fourteen exclusions. The exclusions are listed by section number: sections 5.6.2 through 5.6.2.4; 5.16.2; 5.19 through 5.19.2.2; all of section 7, Performance Requirements for Mesh/Fabric Products; and sections 8.11 through 8.11.2.4, 8.12 through 8.12.2.2, 8.14 through 8.14.2, 8.15 through 8.15.3.3, 8.16 through 8.16.3, 8.28 through 8.28.3.2, 8.29 through 8.29.3, 8.30 through 8.30.5, 8.31 through 8.31.9 and 9.6.1 through 9.6.1.4. We have not read what those sections of the ASTM standard say, so we do not describe them. The Code text states that a free, read-only copy of the standard can be viewed on the ASTM website.
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What the CPSC’s hotel leaflet lists
The CPSC leaflet is titled “Are Your Littlest Guests Well Accommodated?” and is addressed to hotels, motels and other places of public accommodation. The file’s properties show a 2011 creation date, so it describes the rules as they stood when the compliance dates were announced, not the current ASTM editions. It states that after December 28, 2012, places of public accommodation that provide cribs for the use of their guests must provide cribs that comply with the new federal standards, and it lists what the new crib standards do:
- prohibit the sale of traditional drop-side cribs, and immobilizers and repair kits are also not allowed;
- require stronger wood to prevent slat breakage;
- require anti-loosening devices to keep hardware secure and prevent detaching;
- strengthen mattress supports; and
- require more rigorous safety testing.
It also tells operators to purchase new cribs, and not to resell, donate or give away a crib that does not meet the standards; the leaflet recommends disassembling a non-compliant crib before discarding it.
Part 1130: registration, marking and records
Part 1130 applies to “manufacturers, including importers, of durable infant or toddler products”. Its list of durable infant or toddler products includes full-size and non-full-size cribs, play yards, bassinets and cradles, and crib mattresses, among other products. For an imported product, section 1130.2(b) defines the manufacturer as “the importer of the product”. Compliance was required on June 28, 2010 for full-size and non-full-size cribs, bassinets, cradles and play yards, and applies to products manufactured on or after the relevant date.
Section 1130.3 sets three duties on each such manufacturer: provide consumers with a postage-paid registration form with each product; keep a record of the contact information of consumers who register; and permanently place the manufacturer name and contact information, model name and number and the date of manufacture on each product. Section 1130.4 says the mark is permanent if it can reasonably be expected to remain on the product during its useful life, must be in English, legible and conspicuous to the consumer, and gives the date as month and year, which may be coded. Contact information is given as a US address and telephone number, toll free if available.
Sections 1130.5 and 1130.6 specify the registration form: at least the size of two standard post cards joined by perforation, each part at least 3 1/2 by 5 inches, with the purpose statement “PRODUCT REGISTRATION FOR SAFETY ALERT OR RECALL ONLY” and an option to register online. Section 1130.8 requires the manufacturer to keep the registrant record for not less than 6 years after the date of manufacture and to make it available within 24 hours on the request of a CPSC officer, employee or agent. For a buyer that imports cribs in its own name, those duties fall on the buyer.
What to put in the brief
For a US hotel project that includes cribs, play yards or similar infant sleep products, these requests can be settled with each bidder before an order is placed. They are evidence requests, not a legal checklist.
- Which part applies to each product, 1219 or 1220, stated against the interior dimensions in the table above, and whether a bassinet or cradle is in the package, which falls outside Part 1220 but inside Part 1130.
- The edition of the ASTM standard each test report refers to, set against ASTM F1169-25 for full-size cribs and ASTM F406-24 for non-full-size cribs, and the date of the report.
- The permanent marking on each product: manufacturer name and US contact information, model name and number, and month and year of manufacture.
- The registration form that will be supplied with each product and the website or email address that receives registrations, and who holds the registrant record for 6 years.
- Written confirmation of who is the importer for the shipment, because Part 1130 treats the importer of an imported product as the manufacturer.
- For used or older cribs already in the hotel, a plan to replace those that do not meet the standards, as the CPSC leaflet recommends.
How this sits with an FBM Furniture order
FBM Furniture quotations are EXW as standard, C&F on request, and DDP for certain markets such as the United States. Customs clearance and inland transportation at the destination are handled by the customer unless DDP is quoted, and the proforma invoice records the trade term and the estimated dates for the order. Our United States furniture compliance page sets out the other US rules we reference, and the sourcing notes on hotel rollaway beds and extra beds and hotel beds and headboards cover the other sleeping pieces in a guest room package. The rules above cover infant products, so ask your adviser which party takes the importer role before the order is placed.
Source and date
This article reads 16 CFR Part 1219, Part 1220 and Part 1130 as published on the Electronic Code of Federal Regulations, current to 19 October 2026 and read on 24 October 2026, and the CPSC leaflet linked above. Regulations are amended and standard editions change; check the current text and the CPSC’s own guidance before you rely on any date, edition or marking requirement above.
Frequently asked questions
Do US hotels have to provide cribs that meet the federal standards?
Yes, if they provide cribs. Parts 1219 and 1220 each state that places of public accommodation affecting commerce were required to comply on December 28, 2012, which applies to their offer or provision for use of cribs. A hotel is within the definition as an inn, hotel or other establishment that provides lodging to transient guests.
What is the difference between a full-size and a non-full-size crib?
Part 1219 covers cribs within ±5.1 cm (±2 in.) of an interior size of 71 cm by 133 cm (28 5/8 by 52 3/8 in. with tolerances). Part 1220 covers cribs whose interior length is above 139.7 cm or below 126.3 cm, or whose width is above 77.7 cm or below 64.3 cm, including portable cribs, crib pens, specialty, undersize and oversize cribs.
Which ASTM standards do the rules adopt?
Section 1219.2 adopts ASTM F1169-25 for full-size cribs, approved December 15, 2025. Section 1220.2 adopts ASTM F406-24 for non-full-size cribs, approved August 1, 2024, with fourteen exclusions of listed sections. Check the Code for the edition in force before relying on a test report.
Are bassinets and cradles covered by the non-full-size crib rule?
No. Part 1220 excludes cradles, bassinets (junior cribs), baby baskets, car beds, mesh/net/screen cribs and nonrigidly constructed baby cribs from the definition. Part 1130 on registration still lists bassinets and cradles among durable infant or toddler products.
What does Part 1130 require of an importer of cribs?
Section 1130.2(b) treats the importer of an imported product as the manufacturer. The manufacturer provides a postage-paid registration form with each product, keeps the registrant record for at least 6 years after the date of manufacture, and permanently marks each product with its name and contact information, model name and number, and date of manufacture.
How does FBM Furniture support a hotel guest room package?
We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and your team is welcome to attend.
Planning a guest room package for a United States hotel?
Send your guest room schedule and drawings. Our team will review them and get back to you.