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15236hon.kon

Mr. Raymond Ho
Transport Department
Room 3501
Hopewell Centre
183 Queen's Road
East Wan Chai
HONG KONG

Dear Mr. Ho:

This responds to your letter to the National Automobile Dealers Association (NADA), a private organization that represents automobile dealers, asking about the "latest list of approved types and standards of seat belts and child restraints." NADA referred your letter to the National Highway Traffic Safety Administration (NHTSA), because NHTSA is the Federal agency that regulates motor vehicle safety in this country.

You indicate that you would like our latest list of approved seat belts and child restraints to update your list of approved types and standards of the equipment. NHTSA does not keep such a list. This agency does not have a certification process similar to the European Economic Community, in which a manufacturer is required to deliver its equipment to a governmental agency for testing and approval before the product can be sold. Instead, as required by 49 U.S.C. 30101 et seq. ("the Safety Act"), each manufacturer must certify that each of its items of equipment fully satisfies all requirements of the applicable Federal motor vehicle safety standards. In the case of seat belts and child seats, each belt and child restraint that is sold in or imported into the United States must be certified as complying with Safety Standard No. 209 and 213 (49 CFR 571.209 and 571.213), respectively. The standards set forth both performance and labeling requirements that must be satisfied by the belts and the child restraints.

Further, NHTSA does not require that the manufacturer's certification be based on a specified number of tests of the equipment item or on any tests at all. Pursuant to the Safety Act, we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer in the first instance to determine what data, test results, or other information it needs to enable it to certify that its equipment complies with the standards. We would certainly recommend, however, that a manufacturer selling its belt systems or child restraint systems in the United States test those systems according to the test procedures specified in the standards.

I hope this answers your questions. If you need further assistance, please contact Ms. Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:213
d:6/11/97