1. 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.

2. • 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.

3. 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

4. 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

5. 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:

6. 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

7. 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.

8. 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.

9. 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:

10. • 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.

11. 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 ZEALAND
CHOKING HAZARD – INHALATION AND INGESTION.

12. 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

13. 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

14. 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.

15. 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.