Interpretation ID: aiam0387
Secretary-Treasurer
Superex of Ramsey Ltd.
P.O. Box 10
Ramsey
NJ 07446;
Dear Mr. Hanser: This is in reply to your letter of June 10, 1971, in which you stat that you are interested in determining whether a particular child seat meets Federal requirements, and whether you may submit a sample fo (sic) us for approval.; The NHTSA does not furnish approvals, or statements that a particula product complies with an applicable Federal standard. Under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.) it is the responsibility of each manufacturer both to determine that his products comply with any applicable safety standard, and to certify that the product complies in accordance with section 114 of the Act (15 U.S.C. 1403) and the Certification regulations (49 CFR Part 567, copy enclosed).; Manufacturers generally either test their products to the applicabl standards in their own facilities, or contract with an independent test laboratory to perform the appropriate tests. It is up to the manufacturer to determine what means are best suited for his particular product. You should note, however, that the National Traffic and Motor Vehicle Safety Act requires a manufacturer to use due care both in manufacturing his products to comply with applicable standards, and ensuring that his certification that they comply is not false or misleading (Section 108). Violators of those requirements may be subject to civil penalties and other sanctions provided for in the Act (Sections 109 and 110).; A copy of the Act, with the sections specified above marked for you convenience, is enclosed. If you have any questions concerning its application to you, please write to us and we will be happy to answer them for you.; Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs;