Clever Living Products
P.O. Box 274
Rancocas, N.J. 08073
Dear Mr. O'Neill:
This responds to your March 26, 1997, letter asking whether an August 5, 1993, interpretation to you reflects current National Highway Traffic Safety Administration (NHTSA) law and policies.
The answer is yes, the general policies, legal principles and requirements discussed in that letter have not changed. You wrote about an aftermarket toy holder that attaches to a child restraint system by a mounting bracket. Standard No. 213, "Child Restraint Systems," has been amended a number of times since 1993, but still does not apply to aftermarket accessories for child restraint systems. Manufacturers, distributors, dealers, and motor vehicle repair businesses are prohibited from knowingly making inoperative any device or element of design installed on a child restraint system in compliance with Standard 213.
For your information, the "National Traffic and Motor Vehicle Safety Act" to which the 1993 letter refers has been recodified in Title 49 of the United States Code. This means that the citations used in the letter are outdated; however, the substantive requirements it describes have not changed.
If you have other questions, please contact Deirdre Fujita of my staff at (202) 366-2992.
Acting Chief Counsel