Interpretation ID: aiam4034
Comfit Designs
1721 S. La Rosa Drive
Tempe
AZ 85281;
Dear Ms. Jones: Thank you for your letter dated July 29, 1985 inquiring about Federa requirements applicable to children's car seat covers which you manufacture for sale as accessories to child restraint systems.; This agency administers the National Traffic and Motor Vehicle Safet Act of 1966, as amended, 15 U.S.C. 1391 *et seq*. (the Act). Under the Act, the agency has issued Standard No. 213, *Child Restraint Systems*. Paragraph S5.7 of that standard requires each material used in a child restraint system to conform to the requirements of S4 of Standard No. 302, *Flammability of Interior Materials* (49 CFR Section 571.302). These flammability resistance requirements apply to *new* child restraint systems used in motor vehicles or aircraft. The flammability resistance requirements in Standard No. 302 must be met by aftermarket seat covers for child restraint systems only if such seat covers are installed by manufacturers, dealers, distributors, or repair shops. A manufacturer, distributor, dealer, or motor vehicle repair business must not install a seat cover for a child restraint system which does not comply with the flammability resistance requirements of Standard No. 302.; However, aftermarket seat covers which are sold to and installed b child restraint owners need not satisfy the flammability resistance requirements of Standard No. 302. Nevertheless, the agency urges all manufacturers of such seat covers to comply voluntarily with our safety standards.; A copy of Standard No. 302 is enclosed. I hope this information i helpful to you.; Sincerely, Erika Z. Jones, Chief Counsel