kSIST-TP FprCEN/TR 18137:2024
(Main)High chairs and learning towers - Compiled interpretations of CEN/TC 364 standards
High chairs and learning towers - Compiled interpretations of CEN/TC 364 standards
Gathering the responses to the various interpretation requests received over the years into a single document to be referred to.
Hochstühle und Lerntürme - Zusammengestellte Interpretationen zu Normen des CEN/TC 364
Otroški visoki stoli in učni stolpi - Zbrane interpretacije standardov CEN/TC 364
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
01-september-2024
Otroški visoki stoli in učni stolpi - Zbrane interpretacije standardov CEN/TC 364
High chairs and learning towers - Compiled interpretations of CEN/TC 364 standards
Hochstühle und Lerntürme - Zusammengestellte Interpretationen zu Normen des
CEN/TC 364
Ta slovenski standard je istoveten z: FprCEN/TR 18137
ICS:
97.140 Pohištvo Furniture
97.190 Otroška oprema Equipment for children
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
FINAL DRAFT
TECHNICAL REPORT
RAPPORT TECHNIQUE
TECHNISCHER REPORT
August 2024
ICS
English Version
High chairs and learning towers - Compiled
interpretations of CEN/TC 364 standards
Hochstühle und Lerntürme - Zusammengestellte
Interpretationen zu Normen des CEN/TC 364
This draft Technical Report is submitted to CEN members for Vote. It has been drawn up by the Technical Committee CEN/TC
364.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to change without
notice and shall not be referred to as a Technical Report.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2024 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TR 18137:2024 E
worldwide for CEN national Members.
Contents Page
European foreword . 3
Introduction . 4
1 Scope . 5
2 Normative references . 5
3 Terms and definitions . 5
4 Interpretations/clarifications of EN 14988:2017+A2:2024 . 5
4.1 General. 5
4.2 Interpretation CEN/TC 364 N 359 . 5
4.3 Interpretation CEN/TC 364 N 298 . 6
4.4 Interpretation CEN/TC 364 N 244 . 7
4.5 Interpretation CEN/TC 364 N 322 . 8
4.6 Interpretation CEN/TC 364 N 337 . 9
4.7 Interpretation CEN/TC 364 N 243 . 9
4.8 Interpretation CEN/TC 364 N 360 . 10
4.9 Interpretation CEN/TC 364 N 297 . 11
5 Interpretations/clarifications of prEN 18122:2024 . 12
European foreword
This document (FprCEN/TR 18137:2024) has been prepared by Technical Committee CEN/TC CEN/TC
364 “High chairs and learning towers”, the secretariat of which is held by UNI.
This document is currently submitted to the Vote on TR.
Introduction
This document contains replies to requests for interpretation and clarifications with regard to the
understanding of clauses in the standards elaborated within the CEN/TC 364. The replies concern those
requests which have resulted in an interpretation or the decision that no action is necessary.
An interpretation does not have the same status as the text of the standard, nor can it overrule the text of
the standard. However, following an interpretation should give assurance that the relevant clause of the
standard has been correctly applied. An interpretation will only be regarded as a clarification of the
meaning of the standard.
a) Disclaimer:
The information contained herein is for guidance only and does not reflect the formal approval by
CEN or CEN member bodies. It should be noted that the interpretations are neither part of any
standard nor have been referenced in the Official Journal of the European Union.
b) Requests for interpretation:
Requests for interpretations may be submitted by a CEN member body through its national
committee or by a CEN/TC 364 liaison (but not directly by an individual or a company) – in
accordance with the interpretation protocols agreed by CEN/TC 364.
A request for an interpretation may lead to:
1) an interpretation of the standard:
this should reflect a reasonable interpretation of how the standard should be used, while taking
into account:
i) the wording of the standard;
ii) the rationale of the standard;
iii) the history of the standard;
2) a no-action decision:
this is applicable when it is agreed that the standard appropriately specifies how a high chair
and a learning tower article should be assessed;
3) a proposal for an amendment of the standard:
this is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretations are published in WI00364011, which will be updated on a regular basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN
rules.
c) Answers to requests for interpretations:
Since requests for interpretations are submitted through a CEN member body, it is assumed that the
member body will keep itself informed about decisions concerning the request and its progress and
will itself inform the originator of the request as appropriate.
1 Scope
The purpose of this document is to provide replies to requests for interpretations and clarifications of:
— EN 14988:2017+A2:2024, Children's high chairs - Requirements and test methods;
— prEN 18122:2024, Learning towers - Requirements and test methods
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
4 Interpretations/clarifications of EN 14988:2017+A2:2024
4.1 General
Table 1 — Summary table of the request for interpretations classified in the order of the
clauses/subclauses of EN 14988
Clause/Subclause Title Interpretation
CEN/TC 364
Doc.
8.2.3 Unintentional release of the seat height adjustment N 359
mechanism
8.3.2 Entrapment of head N 298
8.4.1 Requirements on compression points N 244
8.8 Strength and durability hazards (Structural integrity, see N 322
A.4.7)
8.9.1.1.1 and 9.3a Requirements on restraint systems N 337
8.9.1.1.2 Requirements for high chair with an active restraint system N 243
8.9.2 Lateral protection N 360
8.12.1 Stability – Requirements N 297
4.2 Interpretation CEN/TC 364 N 359
Question
Clause 8.2.3 the standard reads
In order to prevent unintentional release of the seat adjustment mechanism, one of the following
requirements shall be fulfilled before and after testing in accordance with 8.1.2.1:
a) at least one operating device requires a minimum force of 50 N to activate, with and without test
mass A on the seat, or
b) height adjustment requires the use of a tool, or
c) release is only possible when two independent operating devices are operated simultaneously, or
d) there are two or more automatically engaging locking devices that both cannot be released by one
single action, or
e) height adjustment requires two consecutive actions, the first of which shall be maintained while the
second is carried out.
A lot of highchairs currently sold on the EU market and that are adjustable in height, feature a button on
either side of the seat and located on the front leg of the chair.
The question is related to the condition c) above, to assess whether these 2 independent operating
devices (the 2 buttons) are operated simultaneously.
If, when pushing the button on one side; then pushing the button on the other side, the seat is reengaged
automatically in the position immediately below; can we consider inadvertent release is prevented and
the condition c) is met?
Proposed answer
We think the requirement is intended to prevent sudden drop of the seat, caused by one inadvertent
operation.
Therefore, we consider for such a case, the safety of the product is ensured. By operating the operating
devices separately there is no unexpected drop of the seat and the locking devices automatically reengage
in the next position of use and condition c) is met.
Answer from the TC364
Adjustment of the seat height is made through the operation of two locking devices, which cannot be
operated at the same time by one single action, therefore the height adjustment mechanism complies
with d)
4.3 Interpretation CEN/TC 364 N 298
Question
Clause 8.3.2.1 of the standard says
‘With the exception of the entrance to the seat unit, the two openings for the child’s legs and openings in
the frame above the level of the top surface of the lateral protection, there shall be no holes, gaps or
openings above the seat surface which allow the small torso probe to pass through when tested
according to 8.3.2.2.’
Usually, entrapment hazard happens in openings that are completely bounded; but it is not clear in the
standard.
On the example below, shall the torso probe be applied in the gap between the backrest and the limit of
the lateral protection when the backrest is inclined, if this gap is completely open?
Proposed answer
The standard is not clear: the hazard is entrapment, but the assessment is not limited to completely
bounded openings.
We would consider there is not entrapment hazard here and not apply the torso probe as described in
8.3.2.2
Answer from the convenor/TC364
The requirement aims to cover the entrapment hazard, should the child fall out of the high chairs feet
first through a bounded opening, causing the child being retained and hanged by the head causing
strangulation.
In the cases shown in the pictures, as the openings are not completely bounded, the test is not applicable.
4.4 Interpretation CEN/TC 364 N 244
Question
The last paragraph of Clause 8.4.1 defines the following requirement:
“Hazardous compression points between the tray and the structure shall be assessed by applying a force of
50 N in the most onerous directions on the tray.”
Was it the intention of this requirement to apply the force in any possible direction, i.e. also from below
the tray or sideways?
Or was it the intention of the words “most onerous direction” to refer the application of a downward force
in the position on the tray most onerous for the test to simulate the real use situation when the dishes
are on the tray or the parent is pushing down by hand (maybe while helping the child)?
Proposed answer
The intention was to apply the force in a downward direction in the most onerous position on the tray.
Answer from the convenor/TC364
The intention was to apply the force in a downward direction, that simulates the real use situation in
which a force is applied vertically on the tray, potentially generating compression hazards between the
tray and the armrests in a position that can be reached by the child with its fingers.
An amendment introducing the required modifications to the wording has been prepared by CEN/TC 364
and is going to be submitted to start the CEN Approval Procedure.
The modification introduced is the following:
“ Hazardous compression points between the tray and the structure shall be assessed by applying a
vertical downward force of 50 N in the most onerous position on the tray”.
4.5 Interpretation CEN/TC 364 N 322
Question
The requirement on strength and durability, Clause 8.8.1, says:
[…] After completing all the tests in accordance with 8.8.2, 8.8.3, 8.8.4, 8.8.5, 8.8.6.1, 8.8.6.2 and 8.8.6.3,
the requirements in 8.1, 8.3 and 8.7 shall be fulfilled and the safety and functions of the highchair shall be
unimpaired
The test method for dynamic strength, Clause 8.8.5, describes:
[…]
Place the wood block (5.18) in the centre of the seat.
Position the impactor (5.17) above the wood block and let it drop freely from a height of 75 mm.
[…]
We have met the case on a specific wooden product, on which the seating surface moved forward due to
the impact of the impactor.
After a number of cycles, the impactor does not hit the centre of the seat anymore, causing one impact
after the other, an important displacement of the seat which at the end, disengages from the structure.
We had two options
1. Taking care the impacto
...
Questions, Comments and Discussion
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