Interpretation ID: nht71-2.10

DATE: 03/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 5, 1971, concerning certification of child seating systems. Your letter asks whether the statement, "This (child seating system) conforms to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture shown above," or alternatively the symbol "DOT," may be used to certify that a child seating system complies with Standard No. 213. You also ask whether the certification statement may be placed on the label required on the child seat pursuant to S4.1 of the standard.

The statement that you submit is an adequate certification statement. Furthermore, this statement or a similar statement may be placed on the label required pursuant to S4.1 of the standard, as the certification would therefore be "in the form of a label or tag" on the item of motor vehicle equipment as specified in section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1403).

With reference to use of the symbol "DOT" for certifying child seating systems, while this symbol is presently used by manufacturers to certify other items of motor vehicle equipment, its use as such is only pursuant to specific provisions of the standards. We cannot approve of its use for child seating systems without prior rulemaking.

WE ARE PLEASED TO BE OF ASSISTANCE.