What’s Up With Missing CR Labels?

This article originated in the November/December 2021 issue of Safe Ride News.

Technicians are wise to carefully scrutinize CRs these days. Noncompliant models are appearing more often than in the past, mainly due to online, third-party sellers. The noncompliant car seat of one travel system (sold online with a continually changing name that is currently Comfy Baby) has been ubiquitous. It has a three-point harness and flimsy parts, but what immediately jumps out is the CR’s utter lack of labels.

When CPSTs see this product in the field, they should urge the owner to report it to NHTSA and the Consumer Product Safety Commission (CPSC) and/or do so themselves. Find directions for reporting fakes and other resources here.

Evenflo LiteMaxEvenflo LiteMax
Evenflo Lite Max is an example of a CR with all the labeling required by the U.S. (left), as well as a side that is mostly label-free (right). This space is reserved for the French labels required by Canada, which Evenflo adds to units sold in that country. (Slide the arrows left or right to compare each side of the car seat)

However, while missing labels are a red flag that a CR could be fake, understanding labeling requirements can help CPSTs avoid jumping to false conclusions. In the case of the aforementioned product, noncompliance is evident—there are no labels at all. However, vigilant techs have contacted SRN with concerns about another situation that has become increasingly common: CRs that seem legit but lack labels on one entire side (see photos). The CR may even have guides in the plastic to mark intended label locations. Since labels aren’t in these spots, techs have worried that these CRs could be fake.

What should a CPST make of this? According to Goodbaby International’s Sarah Haverstick, there is very likely no reason for alarm. In the case of that company’s Lite Max model (shown), as well as other models also sold in Canada, those spaces are reserved for the French-language labels that are required when the CR is sold in that country. When a CR made to meet the regulations of both countries is prepared for sale in the U.S., those spots are left empty. According to Haverstick, “This is just a practical way to harmonize our models that are for sale in both countries.”

This solves the mystery of why some models appear rather “bare” on one side. And, since more models are being certified for sale in both the U.S. and Canada, CPSTs may see this situation more often. (Hint: Owner’s manuals contain other clues. For instance, manuals that say “LATCH/UAS” instead of just “LATCH” have been prepared for CRs sold in both the U.S. and Canada, since Canadians use the term Universal Anchorage System, or UAS, instead of LATCH.)

So, labels aren’t required to be on all sides of a CR; wherever they are placed, they simply need to provide the required information.

To check labeling required by FMVSS 213, look over both sides and the underside of the CR. You should find labeling that states the name of the manufacturer, the date of manufacture, and the model number. (This particular information may be under the CR’s padding; on models with a base, it must be on both the CR and the base.) NHTSA also requires other label information, such as warnings about weight limits, a particular description of how snug the harness should be, and a reminder to register the CR in case of recall. There also must be images that show seat belt or LATCH routing for all configurations.

Additionally, NHTSA requires CRs that face rearward to have an airbag warning. Unlike others, this label requirement specifies a location: near the child’s head, on the outer part of the cushion. The CPSC requires RF-only models (“carriers”) to also bear a standard strangulation warning label in that same padding area.

For a list of all the NHTSA-required labels, see the text of section S5.5 “Labeling” in FMVSS 213; links to federal standards can be found here.

Bottom line: When all the required labeling is present, you don’t need to worry just because a CR seems to have a few “bald spots.” But counterfeiters are getting more and more sophisticated, so CPSTs are encouraged to remain vigilant!