There are a range of options for the government to further intervene, ranging from ‘light’ education-based approaches through to regulation. Each approach has advantages and disadvantages.

MBIE is seeking feedback on 4 options:

• Option 1: further information and education to encourage safe consumer behaviour (e.g. communication programmes, social media campaigns, etc.) only.
• Option 2: government assistance to households to remediate existing hazardous corded window coverings.
• Option 3: voluntary modification measures by businesses to reduce risks (e.g. selling safety devices or cordless designs, providing advice to consumers, etc.), supported by a product safety policy statement under the Fair Trading Act 1986.
• Option 4 (preferred by Government): mandatory product safety regulations, which could be either:
  
  Option 4A: mandatory design requirements for corded window coverings.
  Option 4B: prohibiting window coverings with exposed cords.

For the purposes of this consultation, all options are discussed and analysed separately. However, elements of these options may be combined. In particular, Option 2 (government assistance with remediation) could be implemented separately from other options. Further consumer information and education is also likely to be relevant to the other options, but could be scaled back if it is not solely relied upon.

The table in Appendix 3 summarises the approaches taken by different countries.

Appendix 3 – Table summarising overseas standards

Option 1: Information and education only

Under this option, the Ministry of Business Innovation & Employment (MBIE) would engage in further targeted education to raise awareness of risks and how they can be mitigated and to encourage safe consumer behaviour. This option could help to address risks in homes that already have corded window coverings installed and assist decision-making for new window coverings.

Specific actions may include encouraging caregivers to keep furniture away from windows (to prevent children from accessing window coverings through climbing), position cots away from windows, encourage the use of safety devices, or purchase and substitute cordless products.

The main advantages of this option are that it is low cost and is directed specifically to those who are in the best position to control the risk to children in their care (i.e. parents and caregivers).

The cost of this option would be borne by the government and taxpayers. More work is needed to determine the quantum of funding, which would require identifying appropriate target groups, and the appropriate scale and channels for the campaign. For the purpose of this document, costs are estimated to be $300,000 per annum.*

There are, however, several limitations to this approach, including:

• There may be difficulty targeting homes with corded window coverings where young children live.
• Only some caregivers are likely to take action as a result of an education campaign.
• Cordless designs or appropriate safety devices may be unavailable, difficult to obtain, or too expensive.
• Safety devices may not be effective if they are incorrectly installed, or incorrectly or inconsistently used.­

As mentioned in paragraph 24, MBIE’s consumer awareness survey found that just over half of all respondents were able to identify air restriction from becoming tangled in a corded window covering as a potential cause of harm.

NZIER Corded Blind safety report [PDF, 1.2 MB]

Some consumers and caregivers are likely to take steps to reduce risk, but it is unclear what level of action could be expected. These issues suggest that information and education is a useful complementary option, but may be of limited effectiveness on its own.

* This cost has been estimated based on the cost of MBIE’s past product safety campaigns. Greater funding amounts would increase the reach and effectiveness of the campaign.

Option 2: Remediation with government assistance

This option would provide financial assistance to parents and caregivers to install safety measures or update window coverings to cordless designs. Safety measures may include installing cleats on window frames to wrap outer cords around or installing break-away clips that snap away if excessive force is applied.

This option would help to address any affordability barriers to addressing corded window covering risks.

There are a number of ways this option could be targeted or scaled. This option could be scaled through the range of products that are determined to be eligible for assistance. For example, financial assistance may be provided to cover some or all of the following:

• The cost of safety devices. Cleats that wrap cords around to shorten them and keep them out of children’s reach cost from $10 for a pack of 5. Break-away safety clips that minimise the risks of Roman blinds or beaded cords cost from $6 for a pack of 30 pieces.
• The cost of replacing existing corded window coverings with cordless options.
• The cost of installing safety devices or cordless window coverings. This is estimated by NZIER to be around $4 per window (NZIER Corded blind safety report, page 23.)

NZIER Corded Blind safety report [PDF, 1.2 MB]

Further consideration would also need to be given to eligibility criteria and the quantum of government assistance. For example, whether the Government would cover the full cost of remediation, a particular percentage, or provide a lump sum to eligible households.

The benefits of this option are uncertain, as it would greatly dependant on uptake. However, we expect that uptake would be greater than in Option 1, as the financial compensation provided by government decreases the cost to the consumer.

For a number of years, Victoria (Australia) has run programmes that provide free curtain and blind cord safety kits.* An education campaign in 2010 with television advertising and direct communication with early childhood industry stakeholders, local councils and curtain and blind retailers led to orders for 17,000 curtain and blind cord safety kits (NZIER Corded blind safety report, page 37).

If similar uptake were initially achieved in New Zealand, MBIE estimates that a 5-year programme would be expected to save the lives of 0.16 children under 4, or $658,565 present value** over the 5-year period. This assumes that 17,000 safety kits are distributed in the first year, and that uptake falls 20% each year.

The costs of this option would fall on both the government and taxpayers (through the financial assistance) and consumers (who would face the costs that were not covered by government assistance). The distribution of these costs would depend on the scale of government assistance.

Based on the assumptions outlined above, MBIE estimates that, if the government fully subsidised this scheme over a period of 5 years, the cost of this option will be $114,000 to $377,000. In present value terms, this is $101,000 to $334,000.

The disadvantages of this option are that it may be difficult to target those parents and caregivers who require assistance (rather than those who would implement safety measures in any case). Installation of some safety devices would still require parents and caregivers to use them correctly and consistently.

* Curtain and blind cord safety(external link) — Consumer Affairs Victoria

** Benefit is calculated based on the current estimate of the ‘statistical value of life’ as discussed in paragraph 38.

Option 3: Voluntary measures by businesses to improve the safety of window coverings

Under this option, MBIE would continue encouraging businesses to improve the safety of the corded window coverings that they sell. Acting on the information provided by MBIE, retailers may:

• stock cordless designs in preference to corded designs
• adapt their corded window coverings so they present a lesser risk, e.g. by covering up blind cords or fitting cord guides that limit the size of loops formed, or
• encourage the use of safety devices by consumers.

This could be supported by the Minister of Commerce and Consumer Affairs formally issuing a product safety policy statement under the Fair Trading Act 1986 to provide guidance on the safety of window coverings.

This approach could have a relatively low cost, with costs borne by the government to develop a product safety policy statement and educate suppliers estimated to be $46,000.

Additionally, these actions may result in consumers paying for more expensive, cordless window coverings*, and costs accruing to suppliers and consumers from supplying and installing safety features. NZIER estimated that the cost of supplying and installing cord tensioners would have a maximum cost between $55.8 and $95.9 million – in present value terms, (NZIER Corded blind safety report, page 24). We have taken this as an indicative cost of comprehensive adoption of voluntary measures.

NZIER Corded Blind safety report [PDF, 1.2 MB]

Both cost and effectiveness would depend on whether the safety measures are correctly used by the consumer, as well as voluntary compliance from the manufacturers, distributors and installers of corded window coverings. Because compliance is voluntary, the expected beneficial impact is uncertain.

This option only directly impacts future installations of corded window coverings, rather than corded window coverings that are already installed in homes.

There is a risk that some businesses would continue to sell corded designs that are considered hazardous, potentially for a cheaper price than businesses that implemented more comprehensive safety measures. This could contribute to inequitable outcomes if lower-income households then purchase hazardous designs due to their relatively low price.

*Comprehensive data is not available for the New Zealand market, but NZIER cites analysis from the U.S. Consumer Product Safety Commission 2018 which estimates that cordless window coverings produced overseas cost an additional 8 to 10% for slatted blinds and 6 to 8% for Roman shades, compared to corded alternatives.

Option 4: Mandatory standards (Government’s preferred option)

This option is compulsory and targets businesses. It entails regulating the future sale of window coverings through a product safety standard under section 29 of the Fair Trading Act 1986. This option could be complemented by education activities which could address the existing risk presented by the corded window coverings that are already installed in people’s houses.

This approach is used by a number of different jurisdictions. The table in Appendix 3 summarises the variety of approaches.

There are 2 main types of safety standards that could be implemented by this approach:

• Option 4A: Regulating safety features on corded window coverings.
• Option 4B: Removing exposed corded window coverings from the future market.

Option 4A: Regulating safety features on corded window coverings

Under this option, mandatory safety standards would be put in place to make exposed cords safer by regulating the design and installation of exposed cord window coverings. For example, this could require that window coverings have cords that are out of reach of young children or break under pressure, or be supplied with cord tensioners or cleats (and warnings and instructions to use them).

This approach has been adopted by Australia, which has 2 sets of regulations for corded window coverings:

‘Trade Practices (Consumer Product Safety Standard – Corded Internal Window Coverings) Regulations 2010‘ regulates the supply of corded window coverings.

This includes requirements that the supply of corded window coverings must be accompanied by:

• a warning label on the retail packaging (if the window covering is supplied in retail packaging)
• a warning label or swing tag attached to the cord, installation instructions
• any components (such as cord tensioners or cleats) specified in the instructions as necessary for cord safety requirements.

Additionally, if a cord guide is supplied with a corded internal window covering, the cord guide must be designed to:

• remain firmly attached to a wall or other structure when subject to a force of 70N for ten seconds
• to prevent the possibility of a cord forming a loop 220 mm or longer at a height of less than 1,600 mm above floor level.

‘Competition and Consumer (Corded Internal Window Coverings) Safety Standard 2014’ regulates the installation of corded window coverings.

This includes requirements that a corded internal window covering must be installed:

• in such a way that a loose cord cannot form a loop 220 mm or longer at less than 1,600 mm above floor level
• using any components specified in the installation instructions as necessary to meet requirements for cord safety.

Since the regulations were introduced, Australia’s rate of deaths associated with cordless window coverings decreased from 0.20 to 0.16. These regulations are expected to become more effective over time as corded window coverings in homes are replaced with compliant window coverings.

Under this option, equivalent product safety standards could be introduced under section 29 of the Fair Trading Act 1986. For the purposes of analysing this option, we have considered the impacts of implementing similar requirements to Australia.

NZIER estimated that supplying and installing cord tensioners to all corded window coverings installed in future could decrease the death to rate one third of the current rate once all corded window covers are replaced, which represents a present benefit of $7.9–12.8 million depending on assumptions about how quickly replacement occurs (NZIER Corded blind safety report, page 24). There would be other monetised benefits arising from injury reduction, such as reduced use of health services, but we do not currently have data on this.

NZIER Corded Blind safety report [PDF, 1.2 MB]

This regulatory option would result in compliance costs for suppliers, which are likely to be passed on to consumers. Information about the possible scale of this increased cost is scarce, and MBIE seeks to use this consultation process to assist in filling the information gaps. Expected costs are likely to mostly come from cord safety component and installation requirements.

NZIER did not estimate the cost of regulating safety features on corded window coverings, but estimated that the cost of supplying and installing cord tensioners would have a maximum cost between $55.8 and $95.9 million (in present value terms) (NZIER Corded blind safety report, page 24). We have taken this as an indicative cost of regulatory requirements that would achieve a similar effect. One limitation of these requirements is that, as with options above, they may require parents and caregivers to install safety devices correctly and use them consistently. As with Option 3, this option also only directly impacts future installations of corded window coverings, rather than corded window coverings that are already installed in homes.

This option would have some cost to government, as it implies monitoring and enforcing compliance. This value has not yet been costed.

Option 4B: Removing exposed corded window coverings from the future market

This option would require all window coverings to be cordless or to have cords completely covered. This option has not been undertaken by any jurisdiction to date.

Introducing standards to remove exposed corded window coverings from the market would eventually decrease the death rate to zero as corded window coverings in homes are replaced. NZIER estimates that the current stock would be totally replaced in 20 to 30 years (NZIER Corded blind safety report, page 13). This results in a present benefit of $11.7 to 19.1 million.

NZIER Corded Blind safety report [PDF, 1.2 MB]

NZIER estimates that replacing the existing stock of window coverings would cost consumers between $169.1 and $290.6 million over 30 years.

This option would have some cost to government, as it implies monitoring and enforcing compliance. This value has not yet been costed.

Questions

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