Interpretation ID: nht72-1.47

DATE: 12/14/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kettler of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: A review of correspondence we sent you on October 6, 1972, (in response to your letter of September 26, 1972, concerning child seating systems you plan to import), has revealed that one statement we made should be clarified.

In the second paragraph of our letter we stated that each "seat must be labeled or tagged with a certification that it conforms to all applicable Federal motor vehicle safety standards." Standard No. 213 (49 CFR 571.213), which applies to child seating systems, does require each child seating system to be labeled with information regarding its safe use, and we refer you to the standard for these requirements. However, with respect to certification, manufacturers are not limited to the method specified in our October 6, 1972, letter (viz., attaching a label to the seat), but may certify in other ways as well. For example, Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), on which the certification requirement is based, states that the certification may also be placed on the outside of the container in which the item is delivered.

We regret that our former letter was incomplete in this regard.