Mr. John A. Meyer
    1 Arkie Albanese Avenue
    Manlius, NY  13104

    Dear Mr. Meyer:

    This responds to your October 3, 2002, letter requesting clarification of the labeling requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, Child restraint systems (49 CFR §571.213). In your letter, you ask if a child restraint with a detachable base is required to have the manufacturer and model information labeled on the base as well as the seating portion of the restraint. The answer to your question is no.

    By way of background, each new child restraint system for use in motor vehicles sold in the United States must comply with FMVSS No. 213. S5.5 of FMVSS requires that each add-on child restraint system shall be permanently labeled with specified information including, among others: (1) the model name or number of the system; (2) the manufacturer’s name; and (3) the month, year, and place of manufacture. S4 of FMVSS No. 213 defines "add-on child restraint system" as "any portable child restraint system;" and "child restraint system" as "any device. . .designed for use in a motor vehicle. . .to restrain, seat, or position children who weigh 50 pounds or less. [1]"

    A detachable base is part of a child restraint system. As long as the labeling requirements are met by the system as a whole, the base is not required to be labeled.

    The Agency recently amended the labeling requirements under FMVSS No. 213 to clarify and simplify child restraint labels and instructions. (67 Federal Register 61523; October 1, 2002.)  In the preamble to that amendment, the agency stated that several labeling issues may need to be addressed through future rulemaking. We will consider the issues raised in your letter prior to the next rulemaking.

    If you have any further questions, please contact Mr. Chris Calamita of this office at (202) 366-0536.


     Jacqueline Glassman
    Chief Counsel


    [1] The agency is considering extending the standard to apply to child restraints recommended for use by children up to 65 pounds.    67 Federal Register 21806; May 1, 2002.