Interpretation ID: 8744
Evenflo Juvenile Furniture Co.
1801 Commerce Dr.
Piqua, OH 45356
Dear Mr. Glover:
This responds to your letter and telephone calls about the child seat registration form you are considering. The form is required by S5.8 of Standard 213, "Child Restraint Systems," and is depicted in figures 9a and 9b of the standard.
You ask whether S5.8(c) permits you to place certain additional information in the shaded area on the form. The information is a bar code that you said on the telephone contains information on "date of manufacture, shift, location and serial number for the product that the card represents." You explain that the bar code is desired because it can be automatically scanned, which would avoid possible "mis-keying" of the information into the data record. Further, you state that the bar code has to be surrounded by a slightly larger unshaded "quiet zone" to enable the scanner to record the bar code information. You are concerned whether NHTSA would conclude that the quiet zone renders a part of the shaded area unshaded.
It is our opinion that a bar code that contains the information you described is permitted in the shaded area (the area outside of the space for the consumer to fill in). S5.8(c) of Standard 213 specifies the information that must be provided on the form and states the following:
No other information shall appear on the postcard, except identifying information that distinguishes a particular child restraint system from other systems of that model name or number may be preprinted in the shaded area of the postcard, as shown in figure 9a.
The bar code, printed in the shaded area, is permitted by S5.8(c). The information provided by the bar code distinguishes a particular child seat from another of the same model name or number. We consider the quiet zone as part of the bar code since it is needed for the bar code to be
reliably read. The quiet zone therefore need not be shaded, since the printed bar code (or any other identifying information permitted by S5.8(c)) itself is not.
Please note that, while the bar code is permitted, the information on the model name or number and date of manufacture must still be in English under S5.8(c). This information must be in English so that a consumer can see that this information has been provided and that only minimal effort is needed to fill out the registration form.
We also wish to note another feature of the form you faxed. Your form has the words "please print" after the instructions to the consumer "just fill in your name and address." "Please print" is not on the form depicted in figures 9a and 9b of Standard 213. In an earlier letter, NHTSA decided that a minor variation in the wording of a warning expressly specified by Standard 213 was permitted when the change clarified the warning and did not make any substantive change to the warning's meaning. (Letter to Mr. McGuigan, December 18, 1980.) Similarly, "please print" is a minor variation to the wording of the instructions that clarifies the instructions and does not substantively change them. Thus, it is permitted.
I hope this information is helpful. Please call Ms. Fujita at (202) 366-2992 if you have further questions.
Sincerely,
John Womack Acting Chief Counsel
ref:213 d:10/20/93