Summary

On December 5, 2023 NHTSA published their Final Rule, altering the requirements of FMVSS 213 for all child restraint systems, beginning December 5, 2024. These changes include, but are not limited to, changes to registration card formatting and information requirements, changes to labeling requirements, changes to dynamic testing requirements, and a new test bench. The changes present in this Final Rule will be implemented in two phases: first, information changes are mandated for all seats manufactured on or after December 5, 2024; second, dynamic testing changes including use of the new frontal bench are mandated for all seats manufactured on or after December 5, 2026. The full final rule can be found here. Early compliance is allowed for both sets of requirements.

The following is a list that provides the highlights of the changes and timing. Please contact us if you’d like more information or to discuss how these changes affect your products.

Key Changes

  1. December 5, 2024 Changes: Amended FMVSS 213
    1. Registration – A revision to allow for more flexibility in electronic registration has been made.
    2. Labeling
      1. A maximum height and weight must be provided for children who can safely occupy the system in each of the seat’s use modes (forward-facing, rear-facing, booster, etc.).
      2. Forward-facing seats can only be recommended for use by children with a minimum weight of 12 kg (26.5 lbs.).
      3. Booster seats can only be recommended for use by children with a minimum weight of 18.4 kg (40 lbs.)
      4. There is a newly incorporated test procedure for testing with a 3YO dummy rear-facing. When testing with the HII-3YO dummy rear facing, the knee stops of the dummy will be removed and the legs of the dummy will be positioned up the vehicle seat back for testing. NOTE: Because this is a test procedure, not directly part of the rule making, exact timing of application of this test procedure is not yet clear.
    3. School buses – A wider range of CRSs designed specifically for use on school buses will be allowed.
  1. December 5th, 2026 Changes: FMVSS 213b
    1. All dynamic testing will be required to be performed on the newly designed test bench. This bench has been designed to represent modern day vehicle rear seats more closely.
      1. Note that this bench will be equipped with both Type I (lap only) and Type II (lap and shoulder) vehicle belts and LATCH. The requirements for testing using a Type I (lap only) vehicle belt will remain in place for all seats manufactured before December 5, 2029.
    2. Changes to dummy usage
      1. Seats recommended for use rear facing by children weighing 10 kg to 13.6 kg (22 to 30 lbs.) will be tested only with the 12MO CRABI dummy and will no longer be required to test with the Hybrid III 3YO dummy.
      2. Seats labelled for children weighing 13.6 kg to 18.2 kg (30 to 40 lbs.) will no longer be tested with the 12MO CRABI dummy. 12MO CRABI dummy will no longer be used in testing for forward facing seats with forward facing limits of 26.5 lbs.
      3. Seats labelled for children weighing 18.2 kg to 29.5 kg (40 to 65 lbs.) will be test only with the Hybrid III 6YO dummy. The Hybrid II 6YO will no longer be used.

 

Changes from the Notice of Proposed Rulemaking

  1. Minor changes have been made to the design of the new bench in FMVSS 213b to increase the strength of the bench and reduce variability during testing.
  2. While the NPRM mentioned the possible retraction of Type I testing requirements, the Final Rule keeps these requirements in place until December 5, 2029.
  3. The Final Rule removes the requirement to test with the 12MO CAMI dummy in forward facing seats if the forward-facing seat is only labeled for use by children above 12 kgs (26.5 lbs.).

Note: this is a high level summary and does not address all changes made. As we have more time to review the update it is possible that we will come to understand it differently than represented here. This summary is provided for reference only.