Interpretation ID: 571.213-car seat hook-Allen

Ms. Joan Allen

P.O. Box 26315

Raleigh, NC  27611

Dear Ms. Allen:

This responds to your May 17, 2013, letter asking about safety regulations for a device you call a car seat hook.  You explain that the device is used to make it easier for a consumer to secure a toddlers car seat.  You ask if the product has to be crashed tested.  This letter explains the requirements of the National Highway Traffic Safety Administration (NHTSA) that apply to your product.  The device is not required to be crash tested.

We understand from your letter and the sample product you sent that the car seat hook is a plastic rod about 18 inches long, shaped into a U at one end, like a narrow umbrella handle.  The car seat hook is intended to assist in attaching a forward-facing child restraint system to the vehicle seat using the lap/shoulder belt.  Your website[1] explains that the car seat hook is to help people who have trouble reaching through the openings for the belt.  The written instructions tell consumers to use the hook to grab the seat belt and pull it through the hole that is located in the back of the car seat. 

By way of background information, the National Traffic and Motor Vehicle Safety Act ("Safety Act," 49 U.S.C. 30101 et seq.) authorizes NHTSA to issue safety standards for new motor vehicles and new items of motor vehicle equipment.  NHTSA does not endorse any vehicles or items of equipment.  Further, NHTSA does not approve or certify vehicles or equipment.  Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.  The agency periodically tests vehicles and items of equipment for compliance with the standards.

There is currently no Federal motor vehicle safety standard that directly applies to an accessory item like the car seat hook.  Under the authority of the Safety Act, NHTSA has issued Standard No. 213, Child Restraint Systems, which specifies requirements for child restraint systems used in motor vehicles.  However, Standard No. 213 applies only to new child restraint systems and not to aftermarket accessories sold for child restraints, such as the car seat hook.  NHTSA does not require you to crash test the car seat hook. 

However, under the Safety Act, your product is considered to be an item of motor vehicle equipment.  As a manufacturer of motor vehicle equipment, you are responsible for any safety-related defects in your product.  I have enclosed an information sheet that briefly describes the responsibilities of manufacturers.  If a manufacturer or NHTSA determines that the manufacturers product contains a safety-related defect, the manufacturer is responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

We wish to point out that States have the authority to regulate the use of child restraints.  Thus, we recommend that manufacturers check with the States to see if there are any requirements of which they should be aware.

I hope this information is helpful.  If you have further questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

                                                                                    Sincerely,

                                                                                    O. Kevin Vincent

                                                                                    Chief Counsel

Enclosure