Is the Hip Hugger a Child Restraint System?
You ask in your letter whether your product is a “child restraint system.” The answer is no. Federal Motor Vehicle Safety Standard No. 213 (49 CFR 571.213) regulates child restraint systems. In S4 of the standard, we define a “child restraint system” as “any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less.” The Hip Hugger positions a seat belt on children and small adults; it does not restrain, seat, or position children. We do not consider the Hip Hugger to position children in a manner that a booster seat positions children to better use a vehicle’s belt system. The Hip Hugger simply locks the belt. The device alone cannot place or arrange the location of a child on a vehicle seat. Is the Hip Hugger a Seat Belt Positioner? You also ask whether your product is a seat belt positioner. At this time, NHTSA does not have a standard or regulation for “seat belt positioners.” Howe
