What’s Up With Missing CR Labels?

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.

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Calling Out Fakes, Knockoffs, and Imposters—NOW A FREE WEBINAR!

UPDATE:  The Lifesavers Conference session mentioned in the following article is now offered as a recorded Safe Kids-hosted webinar.
How to Tell if a Car Seat is Legit—or NOT
Watch it here.

One of the many excellent sessions planned for the Lifesavers Conference (March 15–17 in Tampa, Florida) focuses on noncompliant CRs, a very timely topic. Attendees will hear from a CR manufacturer and a CPST-I who has reported non-compliant CRs seen in the field. In addition, a representative of NHTSA will explain various regulatory considerations of these products.

As a member of the Lifesavers planning committee, SRN’s Denise Donaldson has been gathering examples, both online and in person, of the growing number of noncompliant products seen in this country. Readers who encounter unusual products are urged to share this information by emailing a detailed description and photos to

Manufacturers must self-certify CRs, and most products are designed and sold by trustworthy, legitimate companies. However, the public must be vigilant about noncompliant devices, especially ones presented for sale online by vendors who may feel safely concealed from accountability. Sadly, the online marketplace has certainly made it easier for unscrupulous vendors to sell products in the U.S. and Canada that don’t meet applicable regulations.

As this topic has been hot lately, including in mainstream media, many terms have been used to describe problematic devices. SRN deems it time, therefore, to consider terminology a little more closely.

Legitimate CRs Are FMVSS 213-Compliant

First, it’s important to know what it means for a CR to be “213-compliant”—a legitimate CR. A compliant product meets all the performance, structural integrity, and labeling standards of NHTSA’s Federal Motor Vehicle Safety Standard 213, and it fits the definition of one of the CR types to which the standard applies. Therefore, it must be a product for a child who weighs less than 80 pounds and be a rear-facing CR, forward-facing CR, belt-positioning booster seat, car bed, or harness system. The CR may be an add-on or built-in, and the regulation applies to CRs used in any motor vehicle (including school buses) or aircraft. In state child occupant protection (COP) laws, the use of only FMVSS 213-compliant CRs is specified.  (Note for Canadian readers: Although this article is U.S.-centric, much of the content applies to Canada; replace U.S. terms (like FMVSS 213) with their Canadian counterparts.

Whenever possible, refer to any noncompliant product that poses as or competes with compliant CRs a “device,” rather than a child restraint. That way, the term “child restraint” is reserved for legitimate products that truly meet standards. But, among these non-CR devices, there are different types. SRN suggests CPSTs consider the following categories:


Knockoffs: Devices that are inferior copies of particular 213-compliant CR models. In recent months, SRN has heard about knock-offs of the Doona CR and certain Graco RF-only CRs. The makers of these devices rip off the companies they imitate; even worse, the knockoffs are made of substandard materials that lack the strength and integrity of the real thing, do not meet standards, and are a huge risk to children. Warn caregivers to avoid deals that are too good to be true!

Counterfeits: Devices that appear to be 213-compliant CRs, but do not imitate any particular CR model  Like knockoffs, these devices may make claims that they meet federal regulations. However, they typically have clues to the contrary, such as cheaper-looking parts or missing labels. (Recent examples have been sold online as part of a stroller system.)

Imposters: These devices identify themselves as CRs using the language required by FMVSS 213 (in marketing materials, instructions, and labels). However, they do not meet FMVSS 213’s definition of a CR, so this claim is fraudulent. In addition, imposters often say they meet FMVSS 213 crash standards, but since they don’t qualify as a CR under that standard, these claims are baseless. Some seat belt adjusters are examples of imposters, as are devices with a five-point harness that are installed by wrapping a strap around the vehicle seatback (always a clear no-no in personal vehicles).

Other Confusing Products

Decoys: These devices are like imposters, but the manufacturer steers clear of making fraudulent claims of meeting FMVSS 213.  Nonetheless, promotion of such a product often willfully misleads the public into thinking that it is a legitimate alternative to a CR. For instance, many decoys state a starting weight limit of 80 pounds so as to fall outside the scope of FMVSS 213, yet their packaging and promotional materials show the device in use by much smaller/younger children. Since no rules or laws have been broken, the most that can be done is to educate the public about avoiding these products.

Foreign CRs: These are legitimate CRs that are designed to meet the standards of a foreign country, but not FMVSS 213. People visiting from abroad may use their foreign-made models for short stays (like while on vacation). However, people who plan to live in the U.S. for an extended period of time (for instance, on a work visa) should obtain a 213-compliant model. U.S. citizens should not purchase a foreign model for use in the U.S., and NHTSA should be notified if manufacturers or retailers are found to be offering to ship models that don’t meet U.S. regulations to U.S. addresses.

Stay Up to Date!

The current CR market is especially tricky, with online retailers able to pop up at will (and resurrect themselves elsewhere if called into question).  At the same time, several unusual CR features and designs—many inspired by foreign CRs—are now found in legitimate CRs in the U.S. market. Additionally, the demand for lightweight, portable options has led to the invention of products that manufacturers have carefully tested for safety but that do not strictly meet the FMVSS 213 definition of a CR (for instance, harness-like products that do not utilize a tether or boosters that do not boost). Are these “better mousetraps” by designers who have been thinking outside the box or simply imposters? These are questions regulators may need to address in the coming months.

Readers of SRN can count on coverage of new products—legitimate or otherwise—in this newsletter. Another way to check on a product and/or a CR manufacturer is to see if it’s included on the AAP’s annual product listing of CRs. (Remember, however, that this list is updated annually; while finding a model listed here is a good sign that it is legit, the absence of a model may simply mean it is new to the market, so further research would be necessary.)

In general, CPSTs with concerns about any product are encouraged to follow up. Contact the manufacturer and ask questions. Report lingering concerns to the manufacturer and to NHTSA (click on Report a Problem).

And don’t forget to share with SRN, as well. Hope to see you at the Lifesavers Conference in March!

Government Shutdown Affects CPS

Like all Americans, readers are well aware that the U.S. government was shut down from December 22, 2018, until January 25, 2019, prompting the suspension of activities for all agencies deemed nonessential and furloughing roughly 800,000 federal employees.  The CPS work of some readers may have been directly or indirectly impacted by this situation.  From a macro level, here is what SRN has learned about some key aspects of CPS with respect to this shutdown and shutdowns in general.

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NHTSA Clarifies 15-Passenger Van Regulations

On August 10, a full-size, 2010 GMC Savana van carrying school-aged children on a field trip in New Hampshire left the highway and struck a tree head on. Although the crash was serious, only one of the 13 passengers was seriously injured. “It appears seat belts saved a lot of lives today,” one state trooper told the a regional news affiliate while on-site at the crash. “These children—most or all—were wearing seat belts.”

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NHTSA Proposes Changes to Improve LATCH

Can regulatory amendments help LATCH meet its full potential?

On January 23, NHTSA published a Notice of Proposed Rulemaking (NPRM) regarding updates it plans for FMVSS 225 and 213 in order to improve the usability of the LATCH system. This NPRM is an important step toward improving ease of use and accessibility of lower and tether anchors, a topic that hasn’t been addressed through regulation since LATCH was initially introduced 15 years ago. It outlines some basic proposals for new regulations from NHTSA and seeks comment on the necessity of further regulation.

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Federal Motor Vehicle Safety Standards—Weight Limit Related

Recent Developments Likely to Change CPS Landscape

(Scroll down for “New Rule Will Expand FMVSS 213 Coverage to 80 Pounds, Clarify LA Weights” and “NHTSA Revises Final Rule, But Concedes Little to Petition.)”

This issue of SRN covers some important developments that will have far-ranging effects in the CPS field for years to come.

First, a year after the AAP and NHTSA released updated recommendations for how children should ride, a survey from AAA confirms what we’ve sensed:  there has been significant awareness and acceptance of these new guidelines by the public. The 2011 Safe Kids study of CPS use indicated that parents were already trending toward keeping kids in each stage longer, and the AAA survey shows that the efforts of the past year have further contributed to improvement.

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The Mental Acrobatics Needed to Apply LATCH Weight Limits

As most readers have probably noticed, we are going through a particularly complex period with respect to determining LATCH weight limits.  Most CPSTs have heard about upcoming changes in FMVSS 213 regarding lower anchor weight limits.  NHTSA has ruled that, by next February or sooner, CRs must have instructions and labels limiting use of the lower attachment system to a child weight specific to each CR model.  This weight limit is to be calculated based on the formula “65 pounds minus the CR weight.”  Keeping things interesting, this final rule is under further review, and NHTSA may or may not announce a modification to it in coming weeks.  Though this ruling pertains to CRs only, many vehicle manufacturers indicate in the 2013 LATCH Manual* that they have adopted this same formula to express lower anchor limits (and tether anchor limits, too, in some cases).  So this limit now applies to about half of all vehicle brands.

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Federal Motor Vehicle Safety Standards—Side-Impact Related

Status of CR Side-Impact Regulation

The Department of Transportation’s January 2013 Significant Rulemaking Report provides an update on the status of rulemaking for side-impact CR performance requirements, as well as all other significant projects of NHTSA and other agencies.

The update cites the reason for delay of the next action, a public Notice of Proposed Rulemaking (NPRM), as “additional coordination necessary.” It now indicates a projected NPRM date of February 15, 2013 (after this issue of SRN goes to press). The NPRM will open a public comment period, which is typically 60 to 90 days from the date of posting.

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