The Order organises risk control around a small number of operational concepts drawn from two technical standards and some bespoke definitions it provides. The central concepts are:

• AS/NZS ISO 8124: The Order repeatedly imports and modifies the joint Australian/New Zealand standard AS/NZS ISO 8124.1:2002, titled Safety of toys, Part 1: Safety aspects related to mechanical and physical properties. The Order treats particular clauses of that standard as the compliance yardstick for projectile toys (s 3, s 4, s 5, s 6).

• Projectile toy categories: The Order distinguishes projectile toys by energy-storage mechanism:

  • Projectile toy with stored energy: a toy designed to propel a projectile by means of a discharge mechanism capable of storing and releasing energy, with or without a projectile supplied (s 3).
  • Projectile toy without stored energy: a toy designed to propel a projectile by discharge of energy imparted by a child, with or without a projectile supplied (s 3). The distinction matters because different clauses of AS/NZS ISO 8124 are required for sale (s 4-5).

• Projectile and improvised projectile: The Order adopts the AS/NZS ISO 8124 definition of projectile and supplies its own definition of improvised projectile for this Part. An improvised projectile is any object capable of being used as a projectile but not supplied as the toy’s projectile or indicated to be its intended projectile; the Order lists common examples such as battery, biro cap, coin, marble, matchstick, nail, stick, paperclip, pebble and pencil (s 3). The improvised projectile concept is central to the substituted performance limit in s 6(c).

• Discharge mechanism: This term is taken from AS/NZS ISO 8124 and governs what part of a toy is tested under the referenced clauses (s 3). The Order requires that discharge mechanisms, absent modification by users or others, cannot propel an improvised projectile in free flight beyond a set distance (s 6(c)).

• ANSI A100: For corded internal window coverings the Order imports ANSI/WCMA A100.1-1996 American National Standard for Safety of Corded Window Covering Products and uses its definitions, release test and labelling clauses (s 7).

• Corded internal window covering and its components: The Order defines a corded internal window covering broadly to include interior drapery, hardware or window covering products that incorporate looped bead chains, looped cords or other flexible looped devices in their operation, excluding such elements when used solely as a tie-back (s 7). It separately defines looped bead chain and looped cord (s 7).

• Approved cord release device and small parts cylinder test: An approved cord release device must pass the release test set out in Appendix A of ANSI A100 and, if it is intended to come completely away from the covering when it releases the loop, must not fit entirely into the small parts cylinder referred to in clause 5.2 Small parts test of AS/NZS ISO 8124, whatever its orientation while tested (s 7). That cross-reference links the North American standard’s release mechanism test with the small part assessment under the Australian/New Zealand standard.

• Height and dimensional limits: The Order sets specific numeric limits: 1 600 millimetres is the maximum allowable reach of an exposed loop when the covering is fully lowered (s 8(1)(a)); 300 millimetres is the maximum required horizontal free-flight distance for an improvised projectile from a discharge mechanism without modification (s 6(c)); and 300 millimetres circumference is the maximum loop circumference that provides an exception to the 1 600 millimetre rule (s 8(2)(a)).

• Labelling, tags and written information: The Order mandates a warning label (substantially as to format in ANSI A100 cl 5.1.1 but with substituted words), a warning tag (ANSI A100 cl 5.1.2 but substituting “cots” for “cribs”), and, where a safety device exists, an operational tag explaining its functioning (s 9). It also requires accompanying written information that explains installation of the covering and any safety device and repeats the warning (s 8(1)(c)).

These concepts are the building blocks of the Order’s obligations. The Order links product design to quantifiable measurement tests and to specified text for warnings and tags, thereby converting technical-standard requirements into legal conditions on sale.

The Order speaks primarily to persons who sell the specified goods in the market. The operative prohibitions are framed as conditions on sale: a person must not sell a projectile toy with stored energy unless it complies with clause 4.18.2 of AS/NZS ISO 8124 as modified (s 4); a person must not sell a projectile toy without stored energy unless it complies with clause 4.18.3 as modified (s 5); and a person must not sell a corded internal window covering unless it meets the design, labelling and information requirements set out in s 8 and s 9. Accordingly:

• Manufacturers and importers: They are affected because compliance normally must be achieved before products enter the market to be lawfully sold. For projectile toys the manufacturer or importer must ensure compliance with the referenced clauses of AS/NZS ISO 8124 as modified, including the 300 millimetre limit for improvised projectiles (s 4-6). For corded internal window coverings the manufacturer or importer must design products so exposed loops cannot reach within 1 600 millimetres of the base, or else incorporate a qualifying exception device or loop size, and must provide the required label, tags and written information (s 7-9).

• Retailers and other sellers: The prohibitions apply to any person who sells the goods. Sellers must not offer for sale products that do not satisfy the statutory conditions. They are obligated to ensure that products they sell carry the required labels and tags and are accompanied by the written information mandated by s 8(1)(c).

• Installers and businesses that custom-make coverings: The Order contains a narrow exemption in s 8(3) which removes the written information requirement in s 8(1)(c) for corded internal window coverings that are custom-made for installation by a person in the business of installing internal window coverings. That affects both suppliers who custom-make for such installers and the installers themselves. The exemption is limited to the written information requirement only; the other obligations in s 8(1)(a) and (b) remain unless the other exceptions in s 8(2) apply.

• Designers and test laboratories: Entities responsible for product design and testing are implicated because the Order ties legal compliance to passing or meeting specified tests and measurements from AS/NZS ISO 8124 and ANSI A100 (s 6; s 7). For example, achieving an “approved cord release device” status requires passing the release test in Appendix A of ANSI A100 and satisfying the small parts cylinder requirement in AS/NZS ISO 8124 cl 5.2 (s 7).

• Consumers: While the duty is framed as a seller obligation, consumers (particularly purchasers of corded coverings and parents of young children) are affected by the presence or absence of the mandated labels, tags and written instructions that the Order requires sellers to supply (s 8-9). The warning label language specifies an intended audience and hazard focus, warning of strangulation risk to children under five (s 9(1)(a)).

• Others who modify products: The projectile toy clause expressly conditions a performance limit on the absence of user or third party modification: discharge mechanisms must not, without modification by the user or another person, propel improvised projectiles beyond 300 millimetres (s 6(c)). This language indicates that post-sale modification by third parties or users can defeat the statutory safety baseline, which affects parties who modify toys after sale.

The Order does not identify enforcement agencies or specify civil or criminal penalties within its own text. It records administration in the Department of Justice, which indicates where administrative responsibility lies (end note), but the instrument itself frames obligations as statutory sale conditions without embedding sanctions in the text provided.

The Order establishes a compact set of duties on persons selling the two regulated product types and prescribes design and information obligations tied to imported standards. It does not set out private rights or remedies or internal enforcement procedures in the text supplied. The principal duties are:

• Prohibition on selling non-compliant projectile toys: A person must not sell a projectile toy with stored energy unless the toy complies with clause 4.18.2 of AS/NZS ISO 8124 as modified by the Order (s 4). Similarly, a person must not sell a projectile toy without stored energy unless it complies with clause 4.18.3 as modified (s 5). These are strict conditions on sale: compliance with the referenced standard clauses, taking into account the Order’s modifications (s 6), is the statutory precondition for sale.

• Modified standard performance requirement: The Order modifies AS/NZS ISO 8124 by deleting specific subclauses and substituting a concrete performance limit for discharge mechanisms. The substituted clause requires that the toy's discharge mechanism must not, without modification by the user or another person, be capable of propelling an improvised projectile in free flight for a horizontal distance of more than 300 millimetres when discharged horizontally (s 6(c)). This converts what might otherwise be a more general standard requirement into a quantifiable metric.

• Design and labelling duties for corded internal window coverings: A person must not sell a corded internal window covering unless it:

  • is designed so that any exposed looped bead chain, looped cord or other flexible looped device cannot extend to within 1 600 millimetres above the base of the covering when the covering is fully lowered (s 8(1)(a));
  • carries the label and tags required by clause 9 of the Order (s 8(1)(b)); and
  • is accompanied by written information explaining installation of the covering, installation and functioning of any safety device, and repeating the prescribed warning (s 8(1)(c)).

• Exceptions to the 1 600 millimetre design rule: There are three exceptions in s 8(2) which operate as alternative compliance routes to the 1 600 millimetre design duty:

  • loops incapable of forming a loop with circumference more than 300 millimetres comply (s 8(2)(a));
  • the presence of a tension device that complies with clause 6.5.4 of ANSI A100 is acceptable (s 8(2)(b));
  • the presence of an approved cord release device, as defined in s 7, is acceptable (s 8(2)(c)).

• Labelling specifics: The warning label must comply with clause 5.1.1 of ANSI A100 or be the same except that the labelling words are replaced by the Order’s specific warning text stating: WARNING Looped cords, looped bead chains or other flexible looped devices may cause a strangulation hazard for children under 5 years. KEEP CORDS AND CHAINS OUT OF REACH OF CHILDREN (s 9(1)(a)). The warning tag must comply with clause 5.1.2 of ANSI A100 but must refer to “cots” instead of “cribs” (s 9(1)(b)). If the covering includes a safety device, an operational tag explaining how the device functions is required (s 9(1)(c)).

• Tag placement and combination rules: Tags required by s 9 must be attached separately from the warning label (s 9(2)). The Order allows the same tag to satisfy both the warning tag and operational tag requirements if the warning (including pictogram) and the operational explanation are kept distinct and are clear and legible (s 9(3)).

• Custom-made exemption: For corded internal window coverings custom-made for installation by a person in the business of installing internal window coverings, the written information requirement in s 8(1)(c) does not apply (s 8(3)). The exemption is narrowly tailored to that written information obligation; other requirements, such as design or labelling duties, are not expressly excused by s 8(3).

• Definitions that allocate legal effect: The Order defines key terms whose legal effect is to determine whether goods fall within the regulated categories and which tests apply. Definitions include, among others, discharge mechanism, projectile, improvised projectile, projectile toy with stored energy and without, looped cord and looped bead chain, ANSI A100 and AS/NZS ISO 8124 (s 3, s 7). These definitions create the legal perimeter of regulated goods and affect the scope of seller obligations.

The Order does not set out express rights for private parties such as a private right of action or statutory defence formulations, nor does it specify civil or criminal penalties in its own text. It locates administration with the Department of Justice but does not, within the instrument text provided, elaborate enforcement instruments, inspection powers or sanctioning regimes. Consequently, the Order imposes duties by reference to standards and labels, leaving the operationalisation of enforcement to other instruments or authorities not shown in the text supplied.

The Order itself does not contain any express penalty clauses, enforcement powers, or procedural mechanisms for monitoring compliance. Its operative prohibitions are expressed as conditions on sale, but the instrument does not, within the text supplied, specify:

• any criminal offences, monetary penalties or civil consequences for contravening the sale conditions set out in Parts 2 and 3; or
• any investigative, inspection or seizure powers, or the identity of an enforcement agency empowered to act for breach of the instrument’s requirements.

The Order does record administrative and making details that provide indirect pointers to the administrative context. It was made by the Products Safety Committee (the signature block records the Committee chair and the date of the Committee meeting) and it is administered in the Department of Justice. The instrument’s making and notification dates are given (made 20 May 2004; notified in the Gazette on 6 October 2004), and the short title and commencement mechanism are set out (s 1-2).

Given the absence of internal enforcement text, practitioners must look beyond the instrument for the practical enforcement framework. The Order’s obligations are framed as legal conditions on sale, so enforcement, sanctions, compliance monitoring and redress would depend on the legal architecture under which the Products Safety Committee and the Department of Justice operate, or other applicable statutory schemes, instruments or administrative practices. The Order, as provided, does not itself identify those external enforcement instruments.

For compliance work and risk advice, the consequence of the absence of internal penalty provisions is twofold: first, compliance cannot be assured solely by reading the Order; responsible parties need to determine which parent Act, regulations or administrative powers give effect to the Order and set penalties. Second, because the Order ties compliance to technical-standard clauses and numeric thresholds, the practical risk of enforcement will likely depend on whether testing, labelling and documentary evidence are in place to demonstrate compliance to any external regulator or enforcement body that does have statutory powers.

In sum, the Order prescribes duties and technical thresholds but does not, within the instrument itself, state the sanctions or enforcement procedures that would follow a contravention. The Order’s administration is recorded as being with the Department of Justice, and the Products Safety Committee made the instrument.

The Order interacts with external instruments and standards by importing, modifying and cross-referencing them. All interaction statements below are drawn from the text of the Order itself.

• Importation of technical standards: The Order relies on two named technical standards for substantive content. For projectile toys it imports AS/NZS ISO 8124.1:2002 (s 3). For corded internal window coverings it imports ANSI/WCMA A100.1-1996 and also refers to AS/NZS ISO 8124 for certain test methods (s 7). By doing so the Order incorporates technical testing methods, labelling formats and performance criteria from those standards into its legal obligations.

• Modification to imported standards: The Order does not accept the imported standards unaltered. Part 2 expressly modifies AS/NZS ISO 8124 in three respects (s 6):

  • omission of clause 4.18.2(a)(3);
  • omission of clause 4.18.2(b);
  • omission of clause 4.18.2(c) and substitution of a new performance requirement limiting horizontal free-flight distance for improvised projectiles to 300 millimetres;
  • omission of clause 4.18.3(e). These modifications mean that the legal obligations refer to a hybrid instrument: AS/NZS ISO 8124 as modified by the Order, not the standard in its published form.

• Cross-standard testing linkage: For corded internal window coverings the Order requires an approved cord release device to pass the release test in Appendix A of ANSI A100 and, where the device is intended to come completely away from the covering when the loop releases, it must not fit entirely into the small parts cylinder used in AS/NZS ISO 8124 clause 5.2 when tested as that clause prescribes (s 7). This creates an operational link in testing protocols between the ANSI A100 release test and the AS/NZS ISO 8124 small parts test.

• Specific clause references: The Order’s duties refer repeatedly to particular clauses of the standards, including clause 4.18.2 and 4.18.3 of AS/NZS ISO 8124 for projectile toys (s 4-5), clause 6.5.4 of ANSI A100 for a tension device exception (s 8(2)(b)), clause 5.1.1 and clause 5.1.2 of ANSI A100 for label and tag format and content (s 9(1)(a)-(b)), and clause 5.2 of AS/NZS ISO 8124 for the small parts cylinder test (s 7). These specific cross-references mean that compliance requires familiarity with the numbering and substantive tests in those external documents, subject to the Order’s stated modifications.

• Publication and commencement formalities: The Order was made by the Products Safety Committee and is displayed and numbered in accordance with the Rules Publication Act 1953, which the Order acknowledges (closing block). The Order’s commencement mechanism is the day of Gazette notification (s 2), which ties its legal entry into force to statutory publication under the Rules Publication Act framework.

• Administrative placement: The Order records that it is administered in the Department of Justice. While the instrument does not itself specify enforcement powers or sanctions, the administrative placement indicates where oversight and operational administration are to be located. Practitioners must therefore consult the broader legislative and regulatory framework that establishes the Products Safety Committee’s powers and the Department’s enforcement tools, none of which are set out in this instrument.

• Gaps left to external law: Because the Order frames obligations as conditions on sale but does not specify enforcement, penalty or remedial mechanisms, it necessarily interacts with other legal authorities for those functions. The Order’s practical force therefore depends on which broader Acts, regulations, or administrative rules provide sanctioning, inspection or enforcement authority for breaches of sale conditions. Those instruments are not contained in the text before us.

In short, the Order functions as a standards-based, modified incorporation instrument that prescribes conditions on sale by direct reference to clauses within AS/NZS ISO 8124 and ANSI A100. It cross-links tests between those standards and sits within a publication and administrative framework referenced to the Rules Publication Act and the Department of Justice. Enforcement and sanctioning are left to external law and administrative practice not contained in the instrument text.

The Order states its own dates and making authority but contains no recorded subsequent amendments or repeal within the supplied text.

• Making and notification: The instrument was made by the Products Safety Committee at a meeting held on 20 May 2004, and it was notified in the Gazette on 6 October 2004. It takes effect on the day on which its making is notified in the Gazette (s 2; closing block).

• Short title: The Order may be cited as the Sale of Hazardous Goods Order 2004 (s 1).

• Modifications to standards: The Order itself modifies AS/NZS ISO 8124 for the purposes of Part 2 (s 6). Those modifications are part of the Order as made; they are not expressed as later amendments but as operative content of the instrument.

• Absence of later amendments in the instrument: The text provided contains no express amendment history entries, no notes of modification dates or amending instruments, and no repeal provisions. It does not record any superseding instruments or transitional provisions. Therefore, based solely on the supplied text, there are no amendments to report beyond the Order as originally made in 2004.

• Administrative context: The Order indicates display and numbering compliance with the Rules Publication Act 1953 and names the administering department (closing block). Those administrative references are part of the original instrument and not amendments.

• Practical implication for users: Where an instrument sets out compliance by reference to external standards, subsequent changes to those standards potentially matter. The Order, however, fixes compliance to the standards as specified (for example, AS/NZS ISO 8124.1:2002 and ANSI A100.1-1996) and to the modifications the Order prescribes. The Order does not on its face adopt automatically later editions of the referenced standards. Any update to compliance requirements would therefore require a formal amendment to the Order or a new instrument to alter the standards or the Order’s modifications. The supplied text contains no such amendment.

If practitioners need to know whether the Order has been amended after the dates shown, they must consult the official register or subsequent instruments; the Order text itself contains no post‑making amendment record.

The Order’s text contains no references to litigation, judicial determinations, or case law. The instrument records its making by the Products Safety Committee and its notification date, but it does not cite any legal proceedings or judicial interpretation.

• No cases named: The Order does not name any court cases, tribunals or decisions, nor does it indicate judicial review or enforcement action taken under its provisions.

• No declaratory or enforcement actions recorded: The instrument does not record any prosecutions, compliance notices, recalls or enforcement actions. It contains no administrative decisions, and it does not append any tribunal or court outcomes.

• Practical consequence: Because there is no litigation history in the text, legal interpretation of the Order’s provisions will, if required, need to be sought from courts or tribunals in the event of dispute. Any guidance from case law or administrative determinations would be external to the instrument and thus must be located by consulting judicial databases or administrative records beyond this Order.

• Research note: For practitioners preparing compliance advice, contractual terms or litigation strategy, the absence of recorded litigation in the instrument is neutral factual information. It does not indicate how courts would construe terms such as “without modification by the user or another person”, how strictly the numeric thresholds would be enforced, or how exceptions like the custom-made exemption would be applied in practice. Those are matters for tribunal or court interpretation in the event of dispute.

In short, the Order itself contains no litigation history. Any judicial or administrative interpretations relevant to its application will have to be identified in external sources.

This short instrument contains several drafting details and technical cross-references that create practical risks and compliance traps if overlooked. The following are concrete points drawn from the instrument text that practitioners should flag to clients:

• Compliance is to modified standards, not the raw standard: For projectile toys the Order requires compliance with clause 4.18.2 or 4.18.3 of AS/NZS ISO 8124 as modified by the Order (s 4-6). The Order omits specified subclauses and substitutes a new 300 millimetre improvised projectile performance test (s 6). A manufacturer relying on a lab certificate showing compliance with AS/NZS ISO 8124 in its unmodified form may still fail to meet the legal requirement unless the test demonstrates conformity with the Order’s substituted text.

• “Improvised projectile” is broad and example-based: The definition lists many everyday objects (battery, biro cap, coin, game token, marble, matchstick, nail, stick, paperclip, pebble, pencil) and is framed as any object capable of being used as a projectile but not supplied or intended as the toy’s projectile (s 3). This means that tests must consider these types of objects as potential projectiles even if the toy is sold with its own projectiles. The legal metric is whether an improvised projectile could be propelled beyond 300 millimetres absent modification (s 6(c)).

• The 300 millimetre limit is measured in free flight horizontally and applies “without modification by the user or another person”: The substitution in s 6(c) requires testing in a horizontal discharge and excludes cases where the user or another person has modified the toy. The “without modification” phrase could raise evidential issues about post‑sale alteration. Compliance evidence should record as-tested condition and demonstrate that the tested discharge mechanism, as sold, cannot propel an improvised projectile beyond 300 millimetres.

• For corded coverings the 1 600 millimetre rule is a design requirement with three alternative compliance routes: The principal rule prevents any exposed loop extending to within 1 600 millimetres above the base of the covering when fully lowered (s 8(1)(a)). Exceptions exist for loops that cannot form a circumference over 300 millimetres (s 8(2)(a)), for a tension device complying with ANSI A100 clause 6.5.4 (s 8(2)(b)), and for an approved cord release device as defined (s 8(2)(c)). Designers and suppliers must decide which route they intend to rely on and ensure design files, test reports and labelling align with that route.

• Approved cord release device test is cross-standard and has an “orientation” caveat: To be an approved cord release device it must pass Appendix A of ANSI A100 and, if designed to come completely away from the covering when releasing, must not fit entirely into the small parts cylinder specified in AS/NZS ISO 8124 clause 5.2 when tested in that clause’s manner, “whatever the device's orientation” (s 7). The “orientation” caveat could require multiple test positions to ensure the device does not fit the cylinder in any orientation.

• Tag and label separateness and substitution nuances: A required tag must be attached separately from the main warning label (s 9(2)). The Order does permit a single tag to serve both warning and operational functions only where the two elements are kept distinct and legible (s 9(3)). Practical risk: packaging and point-of-sale displays that combine labels and tags in non‑conforming ways may fail to meet the statutory requirement.

• Substituted warning text changes obligations: The warning label must comply with ANSI A100 clause 5.1.1 except that the words of warning are replaced by explicit text that targets children under five and instructs to keep cords and chains out of reach (s 9(1)(a)). Suppliers selling into multiple jurisdictions should not assume that generic ANSI‑format labels suffice; the actual wording must match the Order’s text.

• “Custom-made” exemption is narrow: The written information obligation in s 8(1)(c) does not apply to corded internal window coverings that are custom-made for installation by a person in the business of installing internal window coverings (s 8(3)). The wording limits the exemption to circumstances where the covering is custom-made for such an installer. If a product is custom-made but not expressly for that installer, or if the installer is not a business in that trade, the exemption may not apply.

• The instrument is silent on enforcement mechanisms and penalties: The Order frames duties but contains no penalty or enforcement provisions (see Penalties and enforcement). That silence creates uncertainty about the immediate administrative consequences of non‑compliance and necessitates cross-checking with the broader regulatory framework administering product safety.

• Precision of measurements matters: The Order employs precise numeric thresholds (1 600 mm, 300 mm) and references a specific small parts cylinder test. Compliance requires calibrated measurement and certified testing in accordance with the referenced clauses and the Order’s modifications. Non‑conforming test setup, ambiguous measurement method or incomplete test reports can materially affect legal compliance.

• Products without supplied projectiles still regulated: The definitions make clear that a “projectile toy” may not actually supply a projectile but remains within scope if designed to propel one (s 3). Sellers cannot avoid the projectile toy obligations by omitting a projectile; the design of the toy itself triggers coverage.

These are concrete points grounded in the Order text. Each represents an implementation or interpretation risk that should be addressed by design, testing, labelling and documentation strategies.

Compliance requires combining product design, testing, labelling and paperwork so that the statutory conditions on sale are demonstrably met. The following actions, grounded in the Order text, outline a practicable compliance pathway.

1. Identify which product category applies

   • For toys, determine whether the product is a projectile toy with stored energy or without stored energy as defined in s 3. The distinction determines whether the toy must comply with clause 4.18.2 or clause 4.18.3 of AS/NZS ISO 8124 as modified (s 4-5).
   • For window coverings, determine whether the product is a corded internal window covering (s 7), meaning it incorporates a looped bead chain, looped cord or other flexible loop in operation other than solely as a tie-back.

2. Align design to numeric thresholds and exceptions

   • Projectile toys: Ensure that the toy's discharge mechanism, as sold and without modification by the user or another person, cannot propel an improvised projectile in free flight horizontally more than 300 millimetres (s 6(c)). Document the as‑sold configuration.
   • Corded coverings: Design so exposed looped elements cannot extend to within 1 600 millimetres above the base when fully lowered (s 8(1)(a)), or elect and document reliance on one of the exceptions in s 8(2):
     • limit loop circumference so it cannot exceed 300 millimetres (s 8(2)(a)); or
     • include a tension device complying with clause 6.5.4 of ANSI A100 and retain test/certification records (s 8(2)(b)); or
     • include an approved cord release device meeting the Appendix A release test in ANSI A100 and, where the device comes completely away, demonstrate it does not fit entirely into the AS/NZS ISO 8124 small parts cylinder in any orientation (s 7, s 8(2)(c)).

3. Test to the referenced clauses and the Order’s modifications

   • For projectile toys, obtain a test report that shows compliance with AS/NZS ISO 8124 clause 4.18.2 (stored energy) or clause 4.18.3 (without stored energy) as modified by the Order (s 4-6). Include tests using improvised projectiles where relevant, and record the horizontal free-flight distance.
   • For corded coverings, ensure tests for release devices follow ANSI A100 Appendix A and small parts compliance follows AS/NZS ISO 8124 clause 5.2 where applicable (s 7).

4. Implement the specified label and tag content and placement

   • Prepare a warning label in compliance with ANSI A100 clause 5.1.1 format but substitute the wording required by s 9(1)(a): the precise warning text about strangulation hazard to children under five and the instruction to keep cords and chains out of reach. Maintain the pictogram requirement where applicable by the clause reference.
   • Provide a warning tag in compliance with ANSI A100 clause 5.1.2 but substituting “cots” for “cribs” (s 9(1)(b)).
   • If a safety device is present, provide an operational tag explaining how it functions (s 9(1)(c)).
   • Ensure tags and labels are attached so the warning tag(s) are attached separately from the main warning label, unless the combined tag meets the distinctness and legibility conditions in s 9(3).

5. Provide required written information

   • For corded coverings, supply written instructions that explain how to install the covering, how to install any safety device and how the device is designed to function, and repeat the statutory warning (s 8(1)(c)). Where the product is custom-made for installation by a person in the business of installing internal window coverings, the written information requirement does not apply (s 8(3)); document the transaction to support reliance on the exemption.

6. Maintain documentation and test reports

   • Keep copies of all test reports, design specifications, product drawings showing loop dimensions and device specifications, labelling mockups, tag layout and the accompanying written information. Where an exception is relied on (e.g. tension device, approved release device, loop circumference), retain certification or test evidence demonstrating compliance with the specific clause invoked (s 8(2)(a)-(c); s 7).

7. Quality control and as-sold configuration

   • Ensure production and supply chain controls maintain the tested as-sold condition. The projectile toy clause is explicit that the discharge mechanism must not, without modification by the user or another person, propel an improvised projectile beyond 300 millimetres (s 6(c)). Implement manufacturing controls and packaging tamper evidence to show the product reaches the consumer in the tested configuration.

8. Point-of-sale and distribution checks

   • For retailers and resellers, verify that incoming products carry the required labels, tags and written information before sale. Maintain incoming goods checks and keep supplier certification records.

9. Record the authority basis for compliance choices

   • Where compliance depends on ANSI A100 clauses or AS/NZS ISO 8124 clauses, include references to the specific clause numbers and the Order’s modifications in documentation and internal compliance manuals. Because the Order modifies AS/NZS ISO 8124, confirm that testing and certification reports explicitly address the Order’s substituted requirements (s 6).

10. Seek clarity on enforcement and penalties if necessary

• Because the Order does not itself set out enforcement or penalty mechanisms, identify the parent Act, any regulations, and the administrative arrangements under which the Products Safety Committee operates, and verify how enforcement actions are initiated and what sanctions may apply in practice. The Order records administration in the Department of Justice. Practitioners should verify whether additional statutory instruments or departmental protocols provide powers, notices or fines relevant to non‑compliance.

Takeaway checklist of critical numeric and textual requirements to embed in compliance documentation:

• Projectile toy improvised projectile free-flight horizontal limit: 300 mm (s 6(c)).
• Corded covering maximum exposed loop reach: must not extend to within 1 600 mm above base when fully lowered, unless an exception applies (s 8(1)(a), s 8(2)).
• Loop circumference exception threshold: 300 mm (s 8(2)(a)).
• Specific warning label wording replacing ANSI A100 clause 5.1.1 words, addressing children under five (s 9(1)(a)).
• Warning tag substitution: “cots” for “cribs” per ANSI A100 clause 5.1.2 (s 9(1)(b)).
• Approved cord release device tests: ANSI A100 Appendix A plus AS/NZS ISO 8124 clause 5.2 small parts cylinder criterion where device is intended to come away from covering (s 7).

Following these steps and maintaining disciplined technical and documentary controls will position a seller to demonstrate compliance with the Order’s sale conditions as written.