1288 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

1 49 CFR 571.225, ‘‘Child restraint anchorage 

systems.’’ 

2The 2015 NPRM proposed changes to FMVSS 

No. 213; however, NHTSA recently amended 

FMVSS No. 213 and issued FMVSS No. 213b for 

plain language reasons relating to multiple 

compliance dates of the amendments (88 FR 84514). 

NHTSA decided the requirements would be easier 

to read and understand if the agency issued 

amendments becoming effective on December 5, 

2024, for FMVSS No. 213 and December 5, 2026, 

for FMVSS No. 213b. 

3NHTSA’s 2011–2013 Priority Plan. Link: 

www.regulations.gov/document/NHTSA-2009-0108- 

0032. 

4A full vehicle child restraint anchorage system 

has two lower anchorages and one tether anchorage 

in a designated seating position. 

5Many in the child passenger safety community 

refer to the child restraint anchorage system as the 

‘‘LATCH’’ system, an abbreviation of the phrase 

‘‘Lower Anchors and Tethers for Children.’’ This 

term was developed by a group of manufacturers 

and retailers soon after the 1999 final rule (64 FR 

10786) to educate consumers on the availability and 

use of the anchorage system and for marketing 

purposes. ‘‘LATCH’’ has historically been used in 

various field materials and by NHTSA to refer to 

the vehicle 3-point child restraint anchorage 

system. However, the term has also been used to 

refer to only the lower two anchorages of the 

system, or to refer to the connectors of the child 

restraint system that attach to the lower anchorages. 

Further, NHTSA understands many consumers 

identify the tether anchorage solely with the 

‘‘LATCH’’ system, and thus mistakenly do not 

attach the CRS’s tether strap when using the vehicle 

belt system to attach a child restraint. As such, 

NHTSA has chosen to avoid using the term 

‘‘LATCH’’ in this document where possible to avoid 

ambiguity. 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety 

Administration 

49 CFR Parts 571 and 585 

[Docket No. NHTSA–2024–0089] 

RIN 2127–AL20 

Federal Motor Vehicle Safety 

Standards; Child Restraint Systems, 

Child Restraint Anchorage Systems, 

Incorporation by Reference 

AGENCY: National Highway Traffic 

Safety Administration (NHTSA), 

Department of Transportation (DOT). 

ACTION: Final rule. 

SUMMARY: This final rule amends 

Federal Motor Vehicle Safety Standard 

(FMVSS) No. 225; Child restraint 

systems, and FMVSS No. 213b; Child 

restraint systems, to improve ease-of-use 

of the lower and tether anchorages, 

improve correct use of child restraint 

systems in vehicles, and maintain or 

improve the correct use and 

effectiveness of child restraint systems 

(CRSs) in motor vehicles. This final rule 

fulfills a mandate of the Moving Ahead 

for Progress in the 21st Century Act 

(MAP–21) requiring that NHTSA 

improve the ease-of-use for lower 

anchorages and tethers in all rear seat 

positions. 

DATES: 

Effective date: March 10, 2025. 

IBR date: The incorporation by 

reference of certain publications listed 

in the rule is approved by the Director 

of the Federal Register beginning March 

10, 2025. 

Compliance date: This final rule 

adopts a 3-year phase-in period to 

comply with the updated requirements 

in FMVSS No. 225. The phase-in begins 

on September 1, 2028, and requires that 

20 percent of a manufacturer’s 

applicable vehicles produced from 

September 1, 2028, to August 31, 2029, 

comply with the updated FMVSS No. 

225, followed by 50 percent from 

September 1, 2029, to August 31, 2030, 

and 100 percent on and after September 

1, 2030. Early compliance is permitted. 

Reconsideration date: If you wish to 

petition for reconsideration of this rule, 

your petition must be received by 

February 21, 2025. 

ADDRESSES: Petitions for reconsideration 

of this final rule must refer to the docket 

number set forth above and be 

submitted to the Administrator, 

National Highway Traffic Safety 

Administration, 1200 New Jersey 

Avenue SE, Washington, DC 20590. 

Note that all petitions received will be 

posted without change to 

www.regulations.gov, including any 

personal information provided. 

Confidential Business Information: If 

you wish to submit any information 

under a claim of confidentiality, you 

should submit your complete 

submission, including the information 

you claim to be confidential business 

information, to the Chief Counsel, 

NHTSA, at the address given under FOR

FURTHER INFORMATION CONTACT. In 

addition, you should submit a copy, 

from which you have deleted the 

claimed confidential business 

information, to Docket Management at 

the address given above. When you send 

a submission containing information 

claimed to be confidential business 

information, you should include a cover 

letter setting forth the information 

specified in our confidential business 

information regulation (49 CFR part 

512). Please see further information in 

the Regulatory Notices and Analyses 

section of this preamble. 

Privacy Act: The petition will be 

placed in the docket. Anyone is able to 

search the electronic form of all 

documents received into any of our 

dockets by the name of the individual 

submitting the comment (or signing the 

comment, if submitted on behalf of an 

association, business, labor union, etc.). 

You may review DOT’s complete 

Privacy Act Statement in the Federal 

Register published on April 11, 2000 

(65 FR19477–78) or you may visit 

www.transportation.gov/individuals/ 

privacy/privacy-act-system-recordsnotices. 

Docket: For access to the docket to 

read background documents or 

comments received, go to 

www.regulations.gov, or the street 

address listed above. Follow the online 

instructions for accessing the dockets. 

FOR FURTHER INFORMATION CONTACT: For 

technical issues, you may call Cristina 

Echemendia, Office of Crashworthiness 

Standards (phone: 202–366–6345). For 

legal issues, you may call Natasha Reed, 

Office of the Chief Counsel (phone: 202– 

366–2992). The mailing address of these 

officials is: National Highway Traffic 

Safety Administration, U.S. Department 

of Transportation, 1200 New Jersey 

Avenue SE, West Building, Washington, 

DC 20590. 

SUPPLEMENTARY INFORMATION: In 

accordance with MAP–21 (Pub. L. 112– 

141), this final rule amends FMVSS No. 

225 1 and 213b 2 to improve the ease-ofuse of child restraint anchorage systems. 

MAP–21 Section 31502 requires the 

Secretary of Transportation (NHTSA by 

delegation) to improve the ease-of-use 

for lower anchorages and tethers in all 

rear seat seating positions if such 

anchorages and tethers are feasible. 

Section 31502 of MAP–21 states that the 

Secretary must issue a final rule unless 

such an amendment to FMVSS No. 225 

does not meet the requirements and 

considerations set forth in subsections 

(a) and (b) of section 30111 of title 49, 

United States Code (the National Traffic 

and Motor Vehicle Safety Act (Safety 

Act)). NHTSA is issuing this final rule, 

as directed by MAP–21, after 

determining that the rule meets the 

requirements and considerations of 

section 30111(a) and (b) of the Safety 

Act. This final rule also fulfils NHTSA’s 

goal of improving the usability of child 

restraint anchorage systems.3

NHTSA published the notice of 

proposed rulemaking (NPRM) preceding 

this final rule on January 23, 2015 (80 

FR 3744). In this final rule preamble, 

NHTSA is using the term ‘‘child 

restraint anchorage system’’ (CRAS) to 

refer to the full vehicle system 4 that is 

designed for attaching a child restraint 

system (CRS) to a vehicle at a particular 

designated seating position (DSP).’’ 5

NHTSA also uses the term ‘‘lower 

anchorages’’ for the lower anchorage 

points of a CRAS. The agency refers to 

the tether securement point as a ‘‘tether 

anchorage.’’ For the CRS, this preamble 


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6 49 CFR 571.225, S1. 

7When NHTSA issued FMVSS No. 225, the 

agency also amended FMVSS No. 213 to require 

child restraint systems to have the CRS connectors 

permanently attached to each child restraint. In the 

case of rear-facing child restraints with detachable 

bases, only the base is required to have the 

components. 

8FMVSS No. 225 requires vehicles with three or 

more forward-facing designated rear seating 

positions to be equipped with child restraint 

anchorage systems at not fewer than two forwardfacing designated rear seating positions and a tether 

anchorage at an additional designated rear seating 

position. If the vehicle has fewer than three 

forward-facing rear designated seating positions, 

fewer child restraint anchorage systems are 

required. 

9 Decina, L., et al., ‘‘Child Restraint Use Survey: 

LATCH Use and Misuse,’’ December 2006, (‘‘Decina 

study’’), DOT HS 810 679, Docket No. NHTSA– 

2006–26735. The Decina study is summarized in 

Appendix A to the NPRM preamble. 

10 Id. 

11 Id. 

12 Docket No. NHTSA–07–26833. A summary of 

the public meeting can be found in Appendix B to 

the NPRM preamble. 

13NHTSA included plans to address the CRAS 

usability concerns raised at the 2007 LATCH public 

meeting in its Vehicle Safety and Fuel Economy 

Rulemaking and Research Priority Plan (2011– 

2013). Docket No. NHTSA–2009–0108–0032. 

14Further background on the development of the 

NPRM can be found in the NPRM preamble. 

NHTSA discusses its reasons for using the UMTRI 

LATCH Usability study, infra, in section III of the 

NPRM (80 FR 3748–3753). 

15 Klinich et al., supra. Link: http://

deepblue.lib.umich.edu/handle/2027.42/90856. The 

report was sponsored by the Insurance Institute for 

Highway Safety (IIHS) for developing IIHS’s rating 

of the usability of the child restraint anchorage 

systems in various vehicles. See IIHS Status Report: 

Vol. 47 No. 3, April 12, 2012. 

uses the following terms to refer to the 

various parts of a child restraint that 

connect to the CRAS, as appropriate: 

‘‘child restraint system connectors’’ (or 

‘‘CRS connectors’’), ‘‘lower anchorage 

connector(s),’’ ‘‘tether anchorage 

connector,’’ ‘‘tether strap,’’ and ‘‘tether 

hook.’’ 

Table of Contents 

I. Executive Summary 

II. Statutory Authority 

III. Summary of the NPRM 

IV. High Level Summary of the Comments 

Received 

V. Improving the Ease of Using Lower 

Anchorages 

a. Attaching to the Lower Anchorages 

b. Post-NPRM Research 

c. Summary of Decision on Assessing 

Usability of Lower Anchorages 

d. Detailed Agency Decisions Regarding 

the Tools and Performance Criteria 

VI. Improving the Ease of Using the Tether 

Anchorage 

a. Attaching to the Tether Anchorage 

b. Tightening the Tether 

c. Noticing the Tether Anchorage 

d. Recognizing the Tether Anchorages 

VII. Conspicuity and Identification of Vehicle 

Anchorages and CRS Connectors 

a. General Comments and Agency 

Responses 

b. Lower Anchorage Marking Comments 

and Agency Responses 

c. Tether Anchorage and Connector 

Marking Comments and Agency 

Responses 

d. Tether Anchorage Marking Comments 

and Agency Responses 

VIII. Applying FMVSS No. 225 to Vehicles 

Currently Excluded 

IX. Public Responses To Request for 

Comments and NHTSA’s Views 

a. Center Rear Seat—Dedicated, Shared or 

No Lower Anchorages 

b. Third Row 

c. Terminology 

d. Recommendation for Tether Anchorage 

Use Regardless of Child Weight 

X. Housekeeping 

XI. Lead Time and Phase-In 

XII. Cost Benefit Analysis 

XIII. Regulatory Notices and Analyses 

I. Executive Summary 

a. Introduction 

This final rule amends FMVSS No. 

225 to improve the usability (ease-ofuse) of the standardized CRASs required 

by the standard. Prior to FMVSS No. 

225, CRSs were anchored to a vehicle 

seat solely by the seat belt. Because seat 

belts are primarily designed for 

passengers and not child restraints, 

incompatibilities existed between seat 

belts and CRSs. NHTSA issued FMVSS 

No. 225 in response to this problem to 

optimize the safety performance and 

ease of the correct use of child restraints 

through a dedicated CRAS. The 

standard aims to reduce the likelihood 

of an anchorage system’s failure and 

increase the likelihood that CRSs are 

properly secured to achieve the CRS’s 

safety benefits during motor vehicle 

crashes.6

The CRAS required by FMVSS No. 

225 entails a 3-point system consisting 

of two lower anchorages and a tether 

anchorage, designed for attaching a CRS 

to a vehicle. Each lower anchorage 

consists of a 6-millimeter (mm) diameter 

straight rod, or ‘‘bar,’’ onto which a CRS 

connector can be attached.7 The two 

lower anchorage bars are typically 

located at or near the seat bight (the area 

where a seat cushion intersects with the 

seatback) in a position where they will 

not be felt by seated adult occupants. 

The tether anchorage is a permanently 

installed vehicle system to which a CRS 

tether hook can be attached.8

CRASs meeting FMVSS No. 225 and 

child restraints meeting the associated 

requirements of FMVSS No. 213 have 

been successfully implemented in the 

fleet since the implementation of 

FMVSS No. 225. According to a 2006 

study by Decina, consumers who use 

the CRAS generally like the system 9

and prefer using lower anchorages to 

attach child restraints to the vehicle 

over seat belt attachments. The study 

also found that CRASs help reduce the 

incorrect installation of child restraints 

(61 percent of CRSs installed with CRAS 

were securely installed compared to 40– 

46 percent of CRSs that were securely 

installed using seat belts).10 However, 

the study found many consumers do not 

use CRASs because they do not know 

enough about the systems.11

Gathered data also indicates that 

many consumers misuse the CRAS or 

find aspects of it difficult to use. 

Specifically, in 2007 NHTSA held a 

public meeting on CRAS to see how the 

systems could be improved.12 Attendees 

repeatedly stated that lower anchorages 

were often embedded deep into the seat 

bight, making it difficult for consumers 

to reach the lower anchorages and 

attach the lower anchorage connectors. 

Attendees also indicated that it was 

difficult to attach lower anchorage 

connectors to the lower anchorages 

because of surrounding stiff cushions, 

stiff fabric/leather, or the proximity of 

seat belt buckles. In response to 

comments received at the public 

meeting NHTSA studied possible ways 

to improve the usability of CRASs.13

NHTSA used the information obtained 

from these studies to assist in 

responding to the 2012 Congressional 

mandate set forth in section 31502(b)(1) 

of MAP–21 in 2012, publishing an 

NPRM on January 23, 2015, to 

commence rulemaking to improve the 

ease-of-use of child restraint anchorage 

systems.14

b. Summary of the Final Rule 

This final rule adopts most, but not 

all, of the proposals in the NPRM to 

improve CRAS ease-of-use. This final 

rule also adjusts several provisions in 

response to comments received on the 

NPRM. 

1. This final rule amends FMVSS No. 

225 to enhance requirements for the 

usability of CRASs. The final rule’s 

requirements are based in part on 

findings from the University of 

Michigan Transportation Research 

Institute (UMTRI) about characteristics 

of the vehicle seat that enhance the 

usability of CRASs (‘‘LATCH Usability 

study’’).15 This final rule adopts a 

‘‘clearance angle’’ for each lower 

anchorage of at least 54 degrees 

(clearance angle relates to the clearance 

around a lower anchorage from 

interfering parts that can make it 

difficult to maneuver the CRS lower 

anchorage connector) and an 

‘‘anchorage depth’’ limit (location of the 

lower anchorage within the seat bight) 


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of less than 25 millimeters (mm). 

Although the 2015 NPRM included an 

‘‘attachment force’’ limit, NHTSA has 

decided not to adopt an attachment 

force requirement in this final rule 

based on comments received and 

additional study by NHTSA. This final 

rule’s clearance angle and anchorage 

depth limit requirements will 

substantially improve consumer ease in 

using the lower anchorages of CRASs. 

2. This final rule modifies the handheld tools used to measure clearance 

angle and anchorage depth proposed in 

the NPRM. Comments received stated 

that the proposed tools yielded 

inconsistent results and were hard to 

use. In response, NHTSA undertook 

several studies, discussed below in this 

preamble, to refine the proposed tools 

and validate their improved 

repeatability and reproducibility in 

measurements. This final rule adopts 

these improved test tools. 

3. This final rule restricts tether 

anchorages from being placed under a 

vehicle seat or hidden under vehicle 

components other than a marked tether 

anchorage cover. The rule also restricts 

how close the tether anchorage can be 

from the child restraint, (a too-close 

tether anchorage can make it impossible 

to tighten the tether strap properly), but 

does not adopt the location 

requirements that were detailed in the 

NPRM. Some vehicle manufacturers 

stated that the proposed requirements 

were too restrictive, involved a 

procedure that was not executable in 

certain vehicles, or would result in 

costly redesign. The procedure adopted 

in this final rule is less restrictive than 

those proposed in the NPRM, is clear to 

execute, and in some cases affects the 

re-location of the tether by a shorter 

distance or not at all. NHTSA is also 

giving more lead time coupled with a 3- 

year phase-in of the requirements to 

lessen the burdens of redesigning 

vehicles and to reduce costs. 

4. This final rule amends FMVSS No. 

225 to make tether anchorages easier to 

use by standardizing the configuration 

of the anchorage such that it is ‘‘a rigid 

bar of any cross-section shape.’’ 

However, in response to comments, the 

rule allows vehicles with unique space 

limitations in the vehicle interior, such 

as buses, light trucks, and convertibles, 

to have flexible anchorages that can also 

be used as a tether strap routing device. 

5. This final rule standardizes the 

markings that will indicate to 

consumers the location and presence of 

the lower anchorages and the tether 

anchorage. These new markings are 

based on improved anchorage marking 

designs developed by the International 

Standardization Organization (ISO). 

Specifically, this final rule amends 

FMVSS Nos. 225 and 213b to require, 

among other things, vehicles and CRSs 

to use a standardized symbol to more 

clearly identify vehicle anchorages and 

CRS components that attach to those 

anchorages. With these markings all 

consumers can easily look for the 

specific marks and ‘‘match up’’ the 

symbols on the vehicle to the symbols 

on the child restraint. 

6. This final rule amends FMVSS Nos. 

213b to require the top tether hook and 

attachment hardware on child restraint 

systems to be limited in length, as 

proposed in the NPRM. 

This preamble discusses these 

amendments and others in detail below. 

c. How This Final Rule Differs From the 

NPRM 

Highlighted below are the main 

differences between the NPRM and this 

final rule. More minor changes (e.g., 

how a tool is oriented during a test) are 

not highlighted here but are discussed 

in the sections relevant to the topic. 

The final rule differs from the NPRM 

in the following ways: 

• This final rule does not adopt the 

proposed requirement for maximum 

attachment force of 178 Newtons (N) (40 

lbf) to the lower anchorages to improve 

ease-of-use. NHTSA worked to improve 

the repeatability of the attachment force 

tool and conducted a repeatability and 

reproducibility (R&R) study. Results 

showed that the force measurements 

were not repeatable or reproducible 

enough to be adopted because the force 

attachment tool measurements contain 

too much variance. 

• This final rule fine-tunes the 

proposed Clearance Angle and Depth 

Tools to achieve greater R&R in 

measurements. The improvements to 

the tools address comments on 

variability and subjectivity of the 

measurements. The improved tools 

incorporate new or additional 

instrumentation or features to enable 

consistent and non-subjective 

measurements. 

• This final rule specifies that the 

lower anchorage must be located 25 mm 

or less within the seat bight instead of 

the 20 mm within the seat bight 

proposed by the NPRM. This increase in 

depth measurement takes into 

consideration the manufacturing 

variability across vehicles of the same 

model. 

• This final rule does not adopt the 

proposed requirement for 165 mm 

minimum distance of a tether anchorage 

from a reference point on a vehicle seat 

to provide enough clearance for 

tightening the tether strap. Instead, this 

final rule requires the tether anchorages 

for vehicle seats with no head restraint 

or with adjustable or removable head 

restraints to be located outside of a zone 

bounded by a 325 mm radius sphere 

centered at the R-point of the vehicle 

seat and truncated by a horizontal plane 

located 230 mm below the sphere’s 

center. This change was made to 

address multiple concerns from 

commenters. For example, the new zone 

addresses the difficulty of defining the 

proposed reference point (SB) and uses 

an already defined reference point in 

the standard (R-point). This 

measurement also takes into 

consideration the seat’s depth to 

account for the distance that is routed 

over the seat towards the CRS, 

addressing a concern raised by one 

commenter. The new measurement 

required by this final rule will result in 

fewer vehicle models requiring tether 

anchorage relocation. Additionally, for 

those vehicle models requiring the 

relocation of tether anchorages, the 

relocation distance will, in most cases, 

be reduced. The final rule does not 

require vehicle seats with fixed head 

restraints to comply with the minimum 

distance of a tether anchorage from the 

R-point, as such seats do not have any 

elements that would interfere with the 

installation and tightening of the tether. 

To reduce cost burdens on the vehicles 

that will need redesign, we have 

extended the lead time for 

manufacturers to comply by introducing 

a 3-year phase-in that will begin on the 

first September 1 that is three years after 

publication of the final rule. 

• This final rule revises the proposed 

forward-most allowable tether 

anchorage zone under the seat from the 

‘‘plane parallel to the torso line passing 

through the rearmost point of the 

bottom of the seat’’ to a ‘‘vertical 

transverse plane 120 mm rearward of 

the seating reference point.’’ 

Commenters stated that the proposed 

allowable tether anchorage zone based 

on the rearmost point of the bottom of 

the seat may not be objectively 

determined in some seat designs. 

Additionally, commenters stated that 

some current seat designs with easily 

accessible tether anchorages located 

slightly under the back of the seat may 

not be compliant with the proposed 

tether anchorage zone. This final rule’s 

alternative measurement can be 

objectively determined for all seat 

designs, will allow tether anchorages 

that are on the seatback but still 

accessible, and will prevent tether 

anchorages that are deep under the seat. 

• This final rule provides exceptions 

to the NPRM’s originally proposed 

requirement that all tether anchorages 

be rigid bars. Tether anchorages will not 


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16NHTSA designed FMVSS No. 213 and No. 225 

to require each applicable child restraint to be able 

to attach to a vehicle seat by way of the CRAS, and 

additionally by way of the seat belt (continuing 

what was done prior to the standard, so that child 

restraints could continue to be attached using the 

seat belt, which is at every designated seating 

position in a vehicle). 17 49 U.S.C. 30102(a). 

be required to be rigid bars for buses 

with a GVWR less than or equal to 4,536 

kg (10,000 lb) and for vehicles with 

DSPs where the ‘‘allowable tether zone’’ 

in FMVSS No. 225 falls in an area that 

is only accessible by removing a seating 

component of the vehicle. These 

vehicles can be equipped with tether 

strap routing devices that can be used as 

tether anchorages. Commenters stated 

that flexible tether anchorages (that can 

also be used as routing devices) in 

vehicles such as pick-up trucks are easy 

to use for installing CRSs but would no 

longer be permitted under the proposed 

requirements for rigid tether anchorages. 

If only rigid bar tether anchorages are 

permitted, the allowable locations for 

these tether anchorages would be 

behind the seatback where folding the 

seat or moving the seat forward is 

necessary to access the tether anchorage. 

Such a seat design requires an iterative 

tensioning of the tether to install a CRS, 

which is more time-consuming and 

difficult. Therefore, the agency is 

continuing to allow flexible anchorages 

in vehicle that cannot locate the tether 

anchorage in the allowable zone. 

• This final rule updates the 

tolerances and positioning of lower and 

tether anchorages markings to that 

proposed in response to comments 

received. This final rule increases the 

tolerances of the position of the 

markings from that proposed in the 

NPRM and makes some allowances on 

the position of the markings to 

accommodate a variety of vehicle 

designs. 

• This final rule adopts a 3-year 

phase-in period to comply with the 

updated requirements in FMVS No. 225. 

The phase-in period starts on the first 

September 1 that is three years after the 

publication of the final rule. This 

additional lead time and phase-in 

period will reduce potential tooling 

costs by allowing manufacturers the 

opportunity to make required changes to 

subject vehicles during their regular 

design update cycles. 

d. Rulemaking Goals 

The requirements of this final rule, 

aimed at increasing consumer use of 

CRASs for the installation of CRSs, will 

make the CRASs more conspicuous and 

easy to use.16

If CRASs becomes easier to use 

correctly, more consumers will achieve 

a tight fit of the CRS in the vehicle, 

resulting in reduced child head and 

torso excursions in motor vehicle 

crashes, and thus fewer child head and 

torso injuries from crashes. The goal of 

this rulemaking is supported by studies 

showing that many consumers are not 

aware of or do not fully understand the 

CRASs available in their vehicle. 

Specifically, the 2006 Decina study 

found that many consumers did not 

know about CRASs, that CRASs were 

available in their vehicle, the 

importance of using CRASs to install 

CRSs, or how to properly use CRASs. 

The Decina study also found that users 

attempting to use CRASs generally liked 

the systems, and that drivers with 

experience attaching a CRS using a 

CRAS strongly preferred using a CRAS’s 

lower anchorages over seat belts. 

Moreover, the study found consumers 

were more likely to install a CRS 

correctly using a CRAS than a seat belt. 

Finally, the LATCH Usability study 

found that test subjects who correctly 

used the lower anchorage hardware 

were 3.3 times more likely to achieve a 

tight CRS installation than subjects who 

made errors using the hardware. 

e. NHTSA’s Determination of MAP–21 

Requirements and Considerations 

This final rule satisfies subtitle E, 

Section 31502 of the ‘‘Moving Ahead for 

Progress in the 21st Century Act’’ 

(MAP–21). Section 31502(a) requires 

NHTSA (by delegation of authority 49 

U.S.C. 30111) to initiate a rulemaking 

proceeding to improve the ease-of-use 

for lower anchorages and tether 

anchorages in all rear designated seating 

positions if such anchorages and tether 

anchorages are feasible. Section 

31502(b)(1) of MAP–21 states that, 

subject to exceptions, NHTSA (by 

delegation) must issue a final rule. An 

exception is for an amendment to 

Standard No. 225 which ‘‘does not meet 

the requirements and considerations set 

forth in subsections (a) and (b) of 

section 30111 of title 49, United States 

Code [the National Traffic and Motor 

Vehicle Safety Act (Vehicle Safety 

Act)].’’ As discussed below, NHTSA has 

made such a determination regarding 

the final rule amendments to FMVSS 

No. 225 to improve the ease-of-use of 

the CRAS. 

The provision at 49 U.S.C. 30111(a) of 

the Safety Act authorizes the Secretary 

(NHTSA, by delegation) to prescribe 

Federal motor vehicle safety standards 

that are practicable, meet the need for 

motor vehicle safety, and are stated in 

objective terms. ‘‘Motor vehicle safety’’ 

is defined in the Safety Act as ‘‘the 

performance of a motor vehicle or motor 

vehicle equipment in a way that 

protects the public against unreasonable 

risk of accidents occurring because of 

the design, construction, or performance 

of a motor vehicle, and against 

unreasonable risk of death or injury in 

an accident, and includes 

nonoperational safety of a motor 

vehicle.’’ 17 This final rule meets the 

need for motor vehicle safety because it 

would increase the likelihood that 

CRASs and CRSs will be correctly used, 

thereby reducing the risk of injury to 

restrained children in motor vehicle 

crashes. This final rule improves the 

correct use of CRASs and CRSs by 

requiring the lower anchorages and 

tether anchorage of the CRAS to be more 

accessible, easy to use, and clearly 

labeled so that consumers can easily 

identify and use them. This final rule is 

practicable because a number of vehicle 

and child restraint models already meet 

the requirements of the final rule. 

NHTSA is also providing a substantial 

lead time to meet the requirements. 

Some vehicle seat designs will change 

pursuant to the rule, but the redesigns 

would involve relatively straightforward 

modifications to the existing vehicle 

materials (i.e., the seat cushion); most 

vehicles will not have to change the 

vehicle structure. This final rule is 

objective because the requirements are 

stated in unambiguous terms and 

assessed using tools and procedures 

with demonstrated R&R. 

49 U.S.C. 30111(b) specifies that, 

when prescribing Federal motor vehicle 

safety standards, the Secretary (NHTSA, 

by delegation) must, among other 

things, consider all relevant, available 

motor vehicle safety information, 

consider whether a standard is 

reasonable, practicable, and appropriate 

for the types of motor vehicles or motor 

vehicle equipment for which it is 

prescribed, and consider the extent to 

which the standard will further the 

statutory purpose of reducing traffic 

crashes and associated deaths and 

injuries. NHTSA has determined that 

this final rule is reasonable, practicable, 

and appropriate for the types of motor 

vehicles and child restraint systems for 

which it is prescribed. This final rule 

accounts for challenges that buses and 

light trucks could have in meeting the 

proposed requirement that all tether 

anchorages be rigid bars located in a 

particular zone. Among other things, the 

rule permits these vehicles to have 

tether strap routing devices that can be 

used as the tether anchorage if the rigid 

bar is not feasible. 

NHTSA considered existing industry 

standards and conducted extensive 

research prior to the finalization of this 


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18National Traffic and Motor Vehicle Safety Act 

(Safety Act). 

19The responsibility for promulgation of Federal 

motor vehicle safety standards is delegated to 

NHTSA. 49 CFR 1.95. 

20 49 U.S.C. 30111(a). 

21 49 U.S.C. 30102(a)(8). 

22 49 U.S.C. 30102(a)(9). 

23 49 U.S.C. 30111(b). 

24 Id. 

25See 49 U.S.C. 31502(b)(2). 

26See 80 FR 3747 Section II. Statutory Mandate. 

27S5(a) of FMVSS No. 225. 

28There are vehicles that have solved the 

challenges of providing lower anchorages and tether 

anchorages, proving that solutions are feasible. 

final rule to improve the tools and test 

procedures in existing industry 

standards to ensure objectivity of the 

ease-of-use assessments. NHTSA’s 

assessments indicate that most vehicle 

models and child restraints already 

comply with the requirements of the 

final rule. For products that do not, the 

final rule provides ample lead time for 

modifications to be implemented with 

little to no cost. 

f. Estimated Costs and Benefits 

The agency estimates that the adopted 

requirements for improved usability of 

CRASs would not result in any increase 

in material cost but would entail some 

redesign of vehicle seat features. In 

response to the comments received, 

NHTSA is providing a 3-year phase-in 

period to comply with the updated 

FMVSS No. 225 requirements. The 

phase-in period starts on the first 

September 1 that is three years after the 

publication of the final rule. We believe 

this approach would respond to 

commenters’ concerns and provide 

sufficient time for vehicle 

manufacturers to accommodate any 

redesign of the vehicle seat and rear 

shelf structures to meet this final rule in 

their normal course of manufacture 

without a cost increase. 

NHTSA estimates the cost of ISO 

markings for a set of lower anchorages 

to be $0.07 and that for the tether 

anchorage to be $0.03. The total 

incremental cost of equipping all CRASs 

with appropriate ISO markings is about 

$760,000. The final rule also requires 

similar ISO markings on child restraint 

anchorage connectors, for which the 

agency estimates an incremental cost of 

$970,000. The cost of changing the 

written instructions accompanying the 

vehicle or the CRS to explain the ISO 

markings is expected to be negligible 

(<<$0.01). Therefore, the total cost of 

the proposed rule is estimated to be 

$1.73 million. 

These new usability requirements will 

assist in improving correct (tight) 

installation and increase tether use. If 

there were a 5 percent increase in 

correct installation using the lower 

anchors and a 5 percent increase in 

tether use, the agency estimates that the 

proposed requirements would save 

approximately 3 lives and prevent 6 

moderate to higher severity injuries per 

year. 

II. Statutory Authority 

This final rule is issued under the 

Safety Act 18 (49 U.S.C. 30101 et seq.) 

and MAP–21. 

Under the Safety Act, the Secretary of 

Transportation 19 is responsible for 

prescribing motor vehicle safety 

standards that are practicable, meet the 

need for motor vehicle safety, and are 

stated in objective terms.20 ‘‘Motor 

vehicle safety’’ is defined in the Safety 

Act as ‘‘the performance of a motor 

vehicle or motor vehicle equipment in 

a way that protects the public against 

unreasonable risk of accidents occurring 

because of the design, construction, or 

performance of a motor vehicle, and 

against unreasonable risk of death or 

injury in an accident, and includes 

nonoperational safety of a motor 

vehicle.’’ 21 ‘‘Motor vehicle safety 

standard’’ means a minimum 

performance standard for motor vehicles 

or motor vehicle equipment.22 When 

prescribing such standards, the 

Secretary must consider all relevant, 

available motor vehicle safety 

information, and consider whether a 

standard is reasonable, practicable, and 

appropriate for the types of motor 

vehicles or motor vehicle equipment for 

which it is prescribed.23 The Secretary 

must also consider the extent to which 

the standard will further the statutory 

purpose of reducing traffic crashes and 

associated deaths and injuries.24

MAP–21 

MAP–21 (Pub. L. 112–141) 

incorporates Subtitle E, ‘‘Child Safety 

Standards.’’ Subtitle E, section 31502(a), 

requires that not later than 1 year after 

the date of enactment of the Act, the 

Secretary (NHTSA, by delegation) shall 

initiate a rulemaking proceeding to 

amend FMVSS No. 225 ‘‘to improve the 

ease-of-use for lower anchorages and 

tethers in all rear seat seating positions 

if such anchorages and tethers are 

feasible.’’ NHTSA published the NPRM 

preceding this final rule on January 23, 

2015. Section 31502(b)(1) of MAP–21 

states that, subject to exceptions, the 

Secretary must issue a final rule not 

later than 3 years after the date of 

enactment of MAP–21. An exception is 

for an amendment to Standard No. 225 

which ‘‘does not meet the requirements 

and considerations set forth in 

subsections (a) and (b) of section 30111 

of title 49, United States Code [the 

National Traffic and Motor Vehicle 

Safety Act (Safety Act)].’’ 25

NHTSA interprets section 31502(a) as 

directing DOT to initiate rulemaking to 

improve the ease-of-use of lower 

anchorages and tether anchorages 

currently required by FMVSS No. 225 if 

improved anchorages are feasible.26

This final rule satisfies the mandate by 

adopting requirements that will improve 

the ease with which consumers can 

access and use the anchorages and 

improve the visibility of the anchorages 

so that consumers can more easily 

identify them as parts of a CRAS. 

NHTSA carefully considered the 

potential merits of requiring additional 

CRASs in vehicles, with the NPRM 

requesting comment on whether 

additional lower anchorages and tether 

anchorages should be required in 

vehicles. Manufacturers commented 

that it is difficult to have additional 

CRAS systems due to spacing and 

complex designs that may increase 

misuse of the lower anchorages. 

Following careful consideration and 

review of comments, NHTSA has 

determined the available data does not 

support a safety need to require 

additional CRASs or tether anchorages 

in vehicles already covered under 

FMVSS No. 225. 

The NPRM also requested comment 

on the merits and feasibility of installing 

tether anchorages and lower anchorages 

in vehicles excluded from such 

requirements by the issuance of FMVSS 

No. 225 in 1999. This final rule removes 

the current exclusion from tether 

anchorages for convertible vehicles 27

and vehicles described in FMVSS No. 

225 S5(e) from having to provide lower 

anchorages and a tether anchorage in 

rear designated seating positions. This 

decision was made based on the 

agency’s determination that installing 

the tether and lower anchorages in these 

previously excluded vehicles is 

practicable 28 and, given data showing 

the benefits of tether anchorages and 

CRASs, will meet the need for safety. 

These topics are discussed in greater 

detail below. 

Section 31502 gives NHTSA no 

discretion in issuing a final rule if a rule 

would meet the conditions set forth in 

MAP–21. As discussed above, NHTSA 

has determined that amending FMVSS 

No. 225 as set forth in this final rule 

meets the requirements and 

considerations established in 

subsections (a) and (b) of 49 U.S.C 

30111 and are feasible. Accordingly, 


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29The NPRM also proposed to require vehicle 

and child restraint manufacturers to provide written 

information (e.g., in owners’ manuals) explaining 

the meaning of the ISO markings. 

30The Alliance and Global later merged and 

became the Auto Innovators. This document refers 

to these commenters in the name in which the 

comment was submitted. 

31Fiat Chrysler Automobiles U.S. is now 

Stellantis North America. 

32Consumers Union is the public policy and 

advocacy division of Consumer Reports. 

NHTSA is issuing this final rule as 

mandated by MAP–21. 

III. Summary of the NPRM 

The NPRM proposed to reduce the 

physical difficulties associated with 

attaching a child restraint to the lower 

anchorages and to the tether anchorage, 

and to improve how easily a consumer 

can identify the anchorages and match 

them up with parts on a child restraint 

system. Regarding the physicality of 

using the vehicle’s CRAS, the proposed 

changes to FMVSS No. 225 were based 

on the findings in UMTRI’s LATCH 

Usability study, supra, about 

characteristics of the vehicle seat that 

enhance the usability of CRASs. NHTSA 

proposed the limits on the clearance 

angle, attachment force, and the depth 

of the anchorage in the seat bight to 

address the ease-of-use problems 

described in the Decina study, supra, 

and expressed by various attendees to 

the 2007 public meeting. The NPRM’s 

proposals are further summarized 

below. 

Ease of Using Lower Anchorages 

Although FMVSS No. 225’s current 

requirements for the location of lower 

anchorage bars near the seat bight 

intend for the bars to be accessible, 

some consumers find it difficult to use 

the bars. NHTSA proposed new 

requirements for the bars to improve 

ease-of-use: a minimum ‘‘clearance 

angle’’ of 54 degrees (clearance angle 

relates to the clearance around a lower 

anchorage from interfering parts that 

can make it difficult to maneuver the 

CRS’s lower anchorage connector), a 

maximum ‘‘attachment force’’ of 178 N 

(40 lbf), and an ‘‘anchorage depth’’ of 

less than 20 millimeters (mm)). These 

are the ease-of-use specifications the 

UMTRI LATCH Usability study found to 

correlate with correct child restraint 

installation by test subjects. 

In accordance with the LATCH 

Usability study, NHTSA proposed the 

use of three new tools: one to measure 

clearance angle, another to measure 

attachment force, and a third to 

determine anchorage depth. Clearance 

angle would be measured by a tool 

based on a Society of Automotive 

Engineers (SAE) draft J2893 

recommended practice that attaches to 

the lower anchorages. Attachment force 

would be measured by a force gauge. 

Anchorage depth would be measured by 

a simple tool, similar to one UMTRI 

developed, with a hook-type CRS 

connector marked every 20 mm. The 

NPRM also proposed to incorporate by 

reference drawing packages into FMVSS 

No. 225. 

Ease of Using Tether Anchorages 

FMVSS No. 225 currently requires 

tether anchorages to be located in a 

specified zone and to be accessible 

without the need for any tools other 

than a screwdriver or coin. To improve 

the usability of the tether anchorage, 

NHTSA proposed the following 

requirements to make it easier for 

consumers to recognize and access the 

anchorage. 

• The NPRM proposed to reduce the 

zone in which a tether anchorage must 

be located, to prevent tether anchorages 

from being placed deep under a vehicle 

seat. 

• The tether anchorages would have 

to be accessible without the need for 

any tools and without folding the 

seatback or removing carpet or other 

vehicle components. The tether 

anchorage could be covered with a cap, 

flap, or cover, provided that the cap, 

flap, or cover is specifically designed to 

be opened, moved aside, or to otherwise 

give access to the anchorage without the 

use of any tools and is labeled with a 

specific symbol indicting the presence 

of the tether anchorage underneath. 

• Some tether anchorages are too 

close to a structure, such as a head 

restraint, to allow tightening of the 

tether strap. NHTSA proposed to specify 

a minimum 165 mm (6.5 in) distance 

from a specified reference point on the 

vehicle seat to the tether anchorage so 

that adequate clearance will be provided 

for tightening of the tether strap. 

• Currently, there are some tether 

anchorages made from flexible webbing. 

NHTSA proposed to require that the 

tether anchorage be a standardized rigid 

bar so consumers could more easily 

recognize and find it. 

• NHTSA proposed to limit the 

length of the CRS tether hardware 

assembly (which consists of a tether 

hook and hardware to tighten and 

loosen the tether strap) to 165 mm (6.5 

in) so that the tightening mechanism 

can be easily used in the clearance 

space around a tether anchorage. 

Enhanced Ability To Identify 

Anchorages 

In relation to consumers’ seeing or 

recognizing the anchorages, FMVSS No. 

225 currently requires the lower 

anchorage bars to be visible, or that the 

vehicle seat back be marked showing 

the location of the bars. To improve 

consumers’ ability to see, recognize, and 

use lower anchorages, NHTSA proposed 

to require that motor vehicles be marked 

with a standardized ISO-developed 

marking near the location of each lower 

anchorage bar even when the lower 

anchorage is visible. Similarly, tether 

anchorages would be marked with the 

ISO-developed marking. To complement 

these markings, NHTSA proposed that 

child restraints bear the same ISO 

marking on the lower anchorage 

connectors on the child restraint system 

and on the tether hook or tether strap, 

so consumers could be taught to match 

up the symbols when they attach a 

CRS.29

IV. High Level Summary of the 

Comments Received 

NHTSA received submissions from 30 

entities. The commenters fell into the 

following general categories: vehicle 

manufacturers or associations (the 

Alliance of Automobile Manufacturers 

(Alliance), Association of Global 

Automakers (Global),30 Ford Motor 

Company (Ford), General Motors 

Company (GM), American Honda Motor 

Co., Inc. (Honda), Fiat Chrysler 

Automobiles U.S. (Chrysler),31 Toyota 

Motor North America (Toyota), Porsche 

Cars North America, Inc. (Porsche), and 

Hyundai Motor Company (Hyundai)); 

child restraint manufacturers (the 

Juvenile Products Manufacturers 

Association (JPMA), Britax Child Safety, 

Inc. (Britax), Dorel Juvenile Group 

(Dorel), and Graco Children’s Products, 

Inc. (Graco)); suppliers (Motor and 

Equipment Manufacturers Association 

(MEMA), and HSM Transportation 

Solutions, Inc. (HSM)); auto dealers 

(National Automobile Dealers 

Association (NADA)); forensics experts 

(ARCCA); consumer advocacy groups 

(Advocates for Highway and Auto 

Safety (Advocates), Safe Kids 

Worldwide (Safe Kids), Safe Ride News 

(Safe Ride News); research-associated 

organizations (University of Michigan 

Transportation Research Institute 

(UMTRI), Insurance Institute for 

Highway Safety (IIHS), MGA Research 

Corporation (MGA), Consumer 

Union 32); and other (including private 

individuals). 

There was almost unanimous 

agreement for improving the ease-of-use 

of CRASs. However, commenters varied 

in their support for specific 

requirements in the proposal. Many 

vehicle manufacturers expressed 

concern about the extent of changes 

needed to meet some of the 


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33A ‘‘simulated’’ child restraint anchorage system 

consists of the inboard lower anchorages of the 

CRAS in the two outboard seating positions and the 

tether anchorage in the center seat. NHTSA 

explained in the NPRM preamble that available data 

indicate that simulated CRASs appear crash-worthy 

and acceptable. Given these data, the agency sought 

comment on whether NHTSA should encourage or 

require CRS and vehicle manufacturers to include, 

in instruction manuals, statements that endorse the 

use of simulated CRASs in the rear center seating 

position to consumers who wish to place a CRS in 

that center position. 

34That is, even if the tether or anchorage broke 

in a severe crash, the tethering would have 

attenuated some of the crash forces. 

requirements. Specifically, the 

manufacturers expressed concerns over 

extensive redesign to relocate tether 

anchorages, costs of relocating the tether 

anchorage, and challenges of meeting 

some of the lower anchorage 

requirements given the involvement of 

soft seating surfaces. Some 

manufacturers stated there was no need 

to specify all three requirements 

(clearance angle, attachment force, and 

anchorage depth). Suppliers urged 

NHTSA to provide more flexibility in 

marking vehicle seats to identify lower 

anchorage locations so suppliers could 

avoid extensive redesigns that would 

impose costs on suppliers and vehicle 

manufacturers. Several vehicle 

manufacturers stated that the clearance 

angle, attachment force, and anchorage 

depth test tools did not produce 

repeatable or reproducible 

measurements, stating the proposed test 

procedures were ambiguous and could 

not be followed. Vehicle manufacturers 

generally objected to the proposed 3- 

year lead time as insufficient to account 

for necessary changes. Many vehicle 

manufacturers asked for a phase-in of 

the requirements. 

Commenters split on the issue of 

removing certain vehicle exemptions in 

FMVSS No. 225, such as the exclusion 

of convertible vehicles from the 

requirement to provide tether 

anchorages (S5(a)), or vehicles described 

in S5(e) of the standard from having any 

CRAS. A vehicle manufacturers’ 

association and vehicle manufacturers 

responding to the issue were generally 

opposed to removing the exemptions. 

Consumer advocates and research 

organizations strongly supported 

removing the exemptions. 

Many consumer advocates and 

research groups supported the NPRM 

but contended the proposal should go 

further to improve the ease-of-use of the 

anchorage systems. Consumer advocates 

and individuals described numerous 

problems seen in the field that they 

believed should be addressed. Overall, 

child restraint manufacturers and 

private individuals supported the 

proposal. 

Many commenters responded to 

NHTSA’s questions posed in Section X 

of the NPRM (80 FR 3764). Included in 

this section were questions about 

whether there were safety concerns 

about using a ‘‘simulated’’ CRAS in the 

rear center seating position.33 Most 

commenters concurred they did not see 

safety issues raised using simulated 

CRASs in rear center seating positions, 

provided the child restraint and vehicle 

manufacturer at issue supported such 

use. NHTSA also asked whether its 

education materials should recommend 

that tethers should be used for all 

children regardless of the child’s weight 

in the child restraint, based on data 

indicating inherent benefits stemming 

from the use of a tether.34 Most 

commenters on the issue supported the 

agency’s recommendation that tethers 

should be used by all children 

regardless of weight, but one commenter 

(the Alliance) was opposed due to the 

current strength requirements in FMVSS 

No. 225, which limit the forces a tether 

anchorage can hold. 

Many commenters provided input on 

issues that were outside of the scope of 

the rulemaking. NHTSA may consider 

these ideas for possible future updates 

to FMVSS No. 213 and/or No. 225, but 

generally will not further address 

comments outside the scope of the 

rulemaking in this document. 

V. Improving the Ease of Using Lower 

Anchorages 

a. Attaching to the Lower Anchorages 

The NPRM proposed ease-of-use 

requirements to ensure that vehicle 

manufacturers produce lower 

anchorages that: (a) have sufficient 

clearance around each lower anchorage 

for consumers to maneuver the CRS 

connector to attach to the lower 

anchorage (‘‘clearance angle’’ of 54 

degrees or more); (b) are located such 

that the CRS connector can be attached 

to the bar without applying excessive 

force (‘‘attachment force’’ 178 N (40 

pounds (lbf)) or less); and, (c) are not too 

deep within the seat bight so they are 

easily accessible (‘‘anchorage depth’’ 

twenty millimeters (mm) or less from 

the outer surface of the seat bight). 

General Comments 

Commenters varied in their views 

about the proposed clearance angle, 

attachment force and anchorage depth 

requirements. Consumer advocates 

expressed general support for the 

proposed lower anchorage usability 

requirements. Advocates for Highway 

and Auto Safety (Advocates) stated that 

the strengthening of FMVSS No. 225 

through the proposed revisions will 

likely result in more children being 

properly restrained. Advocates 

concurred with the agency’s view that 

improvement in ease-of-use of the 

CRASs will increase use of CRSs and 

proper child restraint system 

installation, which will in turn improve 

child safety. Consumers Union 

supported the NPRM because, in their 

opinion, CRASs provide an easier and 

more secure installation than seat belts. 

IIHS strongly supported the NPRM, 

stating that IIHS confirmed UMTRI’s 

findings in the real world using data 

from Safe Kids’ car seat checkpoints 

from records of more than 14,000 child 

restraint installations. IIHS found that 

anchor depths less than 4 cm, clearance 

angles greater than 54 degrees, and 

attachment forces less than 178 N (40 

lbf) were associated not only with 

correct use, but also with use of the 

anchorage system. While the commenter 

suggested the attachment force tool 

could be improved, IIHS supported 

incorporating the proposed measures 

into FMVSS No. 225. IIHS stated the 

proposed thresholds are supported by 

real-world and laboratory data. 

In contrast, many vehicle 

manufacturers expressed concerns about 

the proposed requirements for lower 

anchorages. They expressed concern 

about the extent of changes needed to 

meet some of the requirements and the 

difficulties in consistently meeting 

requirements involving measurements 

on soft materials like foam and 

cushions. The Alliance supported the 

goal of establishing ease-of-use 

measurements for the lower anchorages 

but did not agree with the proposed 

requirements and test methods. The 

Alliance commented that only an 

anchorage depth requirement is needed. 

It stated that the LATCH Usability study 

showed the measurement of attachment 

force and clearance angle serve as 

surrogates for anchorage accessibility. 

The commenter stated vehicles with 

anchorages deeper in the seat bight 

generally had a smaller clearance angle 

and higher attachment force in the study 

and that more visible anchorages had 

larger clearance angles and lower 

attachment forces, making the child 

restraint attachment step easier to 

accomplish. 

The Alliance stated that, since the 

proposed requirements for anchorage 

location (anchorage depth) will expose 

the lower anchorages in the vehicle, it 

can be expected that the attachment 

forces will be lowered and the clearance 

angles will increase by design, making 

the attachment force measurement and 

clearance angle measurement 

unnecessary. Similarly, Fiat Chrysler 


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35FCA changed its name in 2020 to Stellantis. 

This preamble refers to the commenter by its name 

on the comment, FCA. 

36NHTSA Technical Report, ‘‘Evaluation of 

LATCH Usability Procedure,’’ Docket No. NHTSA– 

2014–0123–0005. 

Automobiles U.S. (FCA) 35 stated that 

clearance angle, force, and anchorage 

depth are mutually inclusive and 

supported the Alliance’s position that 

relocating anchorages further forward in 

the vehicle will generate similar results 

to the proposed requirements. FCA 

recommended removing the attachment 

force and clearance angle criteria. 

Comments Specific to the Tools 

The NPRM proposed to assess 

clearance angle, attachment force, and 

anchorage depth using a set of 

specialized tools based on the tools used 

in the UMTRI study. Prior to the NPRM, 

NHTSA evaluated the proposed 

procedures and tools in 10 vehicles, 

model years (MY) 2005–2013, and 

concluded that the procedures appear 

objective and repeatable.36

Notwithstanding the agency’s data, 

several vehicle manufacturers raised 

concerns about the usability of the 

proposed test tools and questioned the 

repeatability and reproducibility (R&R) 

of test tools measurements and 

recommended more refinement of the 

tools. 

Clearance Angle Tool (CAT) 

Clearance angle relates to the open 

space around a lower anchorage, free 

from interfering seat components. 

Interfering components can make it 

difficult to maneuver and attach a CRS 

lower anchorage connector. A clearance 

angle requirement facilitates easier 

attachment of a CRS lower anchorage 

connector by ensuring surrounding 

components do not impede access to the 

anchorage. 

NHTSA proposed a clearance angle 

measurement tool, illustrated in figure 1 

in the NPRM, for this final rule. That 

clearance angle tool (CAT) includes a 

load cell with a handle to measure the 

applied vertical force on the tool and a 

potentiometer to measure the angle 

achieved with respect to the horizontal 

plane by the tool during the force 

application. In the proposed test 

procedure, the CAT is attached to a 

lower anchorage. A vertical force of 67 

N (15 lbf) is applied to the tool. The 

angle the tool measures (with respect to 

the horizontal) when that force is 

applied is the ‘‘clearance angle.’’ The 

NPRM proposed to adopt a clearance 

angle requirement of not less than 54 

degrees, as supported by the findings of 

the LATCH Usability study. 

Some of the Alliance members 

commented on their experience with the 

SAE Prototype and UMTRI clearance 

angle test devices. The members stated 

they found those devices difficult to use 

and not sufficiently repeatable. GM and 

FCA commented that oscillations 

caused by the free-hanging weight 

attached to the rotary potentiometer 

resulted in non-repeatable 

measurements. GM recommended 

replacing the rotary potentiometers on 

the CAT with a digital inclinometer 

connected to a data acquisition system. 

FCA commented that without real-time 

readout of the vertical force applied, the 

operator will always overshoot/ 

undershoot the specified vertical load. 

Similarly, GM recommended adding a 

means of indicating the force to the 

operator during the measurement 

process so that the operator is notified 

when 67 N (15 lbf) is achieved. GM and 

the Alliance recommended a small 

diameter cylindrical style load cell with 

a lower range of measurement. GM also 

stated that the multiple pivot points 

between the handle and the load cell 

and between the load cell and the main 

body should be reduced to a single pivot 

at attachment to the main body. 

GM stated that, in some cases, it is 

difficult to apply the vertical force due 

to interference with the seatback. FCA 

commented that an operator will have 

difficulty maintaining 67 N (15 lbf) of 

vertical force even if there was a real 

time display of the vertical force. GM 

recommended that the handle pivot 

point to the main body on the tool be 

moved farther from the connection to 

the lower anchorage to allow more 


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" Potentiometer 

Figure 1. Proposed Clearance Angle Tool (CAT) 
1296 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

37NHTSA–2014–0123–0056. 

clearance between the load cell and the 

seatback. GM indicated that eliminating 

this interference should improve the 

repeatability of the process. GM added 

that the equivalent moment can be 

applied by specifying a lower force 

along with the increased moment arm. 

Attachment Force Tool (AFT) 

Vehicle manufacturers raised 

concerns that the attachment force tool 

did not provide repeatable or 

reproducible results. Ford suggested 

that NHTSA include in FMVSS No. 225 

language that would permit an average 

of several trials (i.e., five trials of each 

anchorage) as criteria for compliance. 

Ford and the Alliance stated that the 

repeatability of this test is very 

dependent on operator skill and 

experience and not adequately 

repeatable and reproducible when used 

by different operators in different labs. 

The Alliance explained that many 

vehicle models feature lower anchorage 

designs that include either a cover or a 

slit in the seat cushion that allows 

access to the anchorage bar. Assuming 

that these types of design are not 

prohibited by the new proposed 

maximum attachment force requirement 

for lower anchorages, the Alliance 

recommended that the test be rerun if 

the test device becomes caught in the 

slit or cover. 

GM commented that the AFT does not 

provide real-time feedback, making it 

difficult to ensure the operator performs 

the insertion force measurement at a 

consistent angle with the 0–45-degree 

range specified. GM noted that this 

would be particularly important if the 

trim interferes with insertion of the tool. 

GM added that the operators found the 

AFT angle difficult to control with the 

short T-handle (see figure 2) while 

trying not to touch the tool beyond the 

load cell. GM found that a digital 

inclinometer was helpful in observing 

the angle and improved its confidence 

in the force data being collected. GM 

recommended that the rotary 

potentiometer be replaced with a digital 

inclinometer including a real-time 

readout for the operator and a signal 

output for data acquisition. GM also 

suggested that the T-handle be replaced 

with a longer axial handle to improve 

control of the insertion angle and to 

avoid touching the tool along the load 

path. 

GM commented that the AFT does not 

indicate to the operator that the switch 

used to detect full engagement of the 

tool on the anchorage bar has been 

activated. GM explained that this lack of 

an indication could result in a ‘‘no 

switch closure’’ event, and that the peak 

attachment force prior to bottoming out 

cannot be determined if this happened. 

GM added that if the AFT was not 

sufficiently perpendicular to the 

anchorage bar, it would be possible to 

mechanically bottom out the tool 

without closing the switch and that the 

perpendicular requirement is dependent 

on the distance the slide pin must travel 

before activating the switch. 

Additionally, GM stated that, depending 

on the lower anchorage style in the 

vehicle, particularly for non-visible 

anchorage bars, it can be difficult to 

determine perpendicularity. 

GM requested that the current tool be 

revised to allow a larger tolerance to the 

range of perpendicularity, as a child 

restraint anchorage connector may be 

attached at a larger range of angles than 

the current tool design. GM suggested 

that this goal may be accomplished by 

lengthening the slide pin or increasing 

the thickness of the slide tab and that 

either solution will allow the slide tab 

to close the switch earlier during 

anchorage bar engagement and increase 

the perpendicularity tolerance. GM also 

recommended that an LED be included 

on the tool to indicate to the operator 

when the switch is closed. 

GM also commented on the 

oscillations caused by the free-hanging 

weight attached to the rotary 

potentiometer. GM noted that, 

depending on the timing, the angle 

value at the time of switch closure could 

be very close to a maximum or a 

minimum of an oscillation. GM 

explained that in the example in figure 

2 of its comment submission,37 the 

oscillation is within the 0 to 45 degree 

force application range specified in the 

proposal; however, these oscillations 

can be eliminated by the utilization of 

a digital inclinometer. GM 

recommended that the rotary 

potentiometer be replaced with a digital 

inclinometer that includes a real-time 

readout for the operator and a signal 

output for data acquisition. GM added 

that the rotational freedom of motion of 

the AFT makes it difficult to control 

without touching the tool beyond the 

load cell and potentially altering the 

force measurement. GM also noted that 

the wiring to the load cell is susceptible 

to damage due to its location relative to 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.027</GPH>

Ttiggerswltch. • ~ : 

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Figure 2. Proposed Attachment Force Tool (AFT} 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1297 

38Figure 3 of GM’s comments can be found in 

Docket No. NHTSA–2014–0123–0056. 

39Evaluation of LATCH Usability Procedure, 

Louden et al., 2014. 

40 IIHS provided drawings of the new tool and a 

more detailed description of its use in its 

comments. See www.regulations.gov/comment/ 

NHTSA-2014-0123-0020. 

41Cicchino JB, Jermakian JS. ‘‘Vehicle 

characteristics associated with LATCH use and 

correct use in real-world child restraint 

installations.’’ Journal of Safety Research. 2015 

June. www.iihs.org/topics/bibliography/ref/2068. 

42Safeguard is a brand that produces push-ontype lower anchorage connectors. 

the handle used to apply the force.38

GM recommended that an in-line load 

cell with a threaded attachment between 

the main body and the handle be 

adopted to alleviate these issues. 

Similarly, FCA commented that the 

potentiometer attached to the weight 

that is allowed to swing freely to 

capture the angle causes oscillations in 

the recorded angle, that at the point in 

time when the switch is triggered the 

attachment force increases drastically, 

the operator’s rate of force application 

can influence the results, and that the 

AFT can interact with the seat cushion. 

Global requested that lateral and 

vertical motions with the proposed tool 

be allowed prior to the application of 

the insertion force perpendicular to the 

center of the anchorage bar to represent 

typical actions taken by the consumer 

when attaching a child restraint to the 

lower anchorages. 

IIHS stated that the agency’s proposed 

changes to the AFT should improve 

repeatability of measurements over the 

tools used in the original IIHS/UMTRI 

research. IIHS provided the following 

two concerns: 

1. IIHS and UMTRI stated the 

recorded attachment force should be the 

peak force from initial engagement with 

the seat cushion until full engagement 

of the tool on the lower anchorage. IIHS 

added that for some vehicles the peak 

force occurs as the tool is inserted 

between the cushions. IIHS stated such 

a peak force will not be captured when 

following the proposed protocol because 

the AFT records the force only at full 

engagement with the lower anchorage. 

2. IIHS explained that the proposed 

changes to the tool do not address the 

off-axis vertical force required to align 

the tool with the lower anchorage.39

IIHS noted this vertical force was not 

measured in NHTSA’s evaluation. 

Instead, the force was assigned 

subjective ratings, making it difficult to 

standardize the measurement procedure 

and limiting R&R. IIHS noted it had 

developed a lower anchorage 

attachment force tool 40 that eliminates 

the need for additional vertical or lateral 

forces. This IIHS-developed tool 

replaces the slide pin, slide tab, and 

spring assembly with a square crosssection guide rod with a convex notch 

that prepositions the tool, aligning it 

with the lower anchorage bar before the 

force is applied. IIHS added that the 

new tool replaces the original depth 

gauge, as the depth scale is inscribed on 

the IIHS revised tool.41 IIHS encouraged 

NHTSA to make further refinements to 

the attachment force tool to remove the 

need for off-axis forces to properly align 

with the lower anchorage bar. 

Hyundai commented that the 

proposed AFT did not represent the 

hardware currently used in CRSs in the 

market. Hyundai stated it observed 100 

percent of forward facing/convertible 

child seats sold at a retail store it visited 

are either the Safeguard clip system 42 or 

a simple hook. Hyundai noted the AFT 

has an exaggerated flat front face that 

requires more effort to insert into the 

seat bight for attachment. Hyundai also 

noted the attachment slot of the tool is 

not tapered, potentially leading to false 

readings if not properly engaged with 

the attachment bar. Hyundai performed 

a comparison evaluation with the 

proposed tool and found that the force 

was reduced by 20–50 percent when 

using a Safeguard attachment clip 

common in the industry. Hyundai 

pointed out that CRS manufacturers 

have already found a solution for 

increasing ease-of-use in attaching 

hardware by only using the Safeguard 

clip system connectors or a simple hook 

system. 

Anchorage Depth Tool (ADT) 

Anchorage depth refers to how deeply 

the lower anchorages are embedded in 

the vehicle seat (usually in the seat 

bight or seatback). The LATCH Usability 

study found that an anchorage depth of 

less than 20 mm within the seat bight 

is associated with a significantly higher 

rate of correct lower anchorage use than 

anchorage depths of 20 mm or more. 

NHTSA proposed a requirement for 

each lower anchorage to have an 

anchorage depth of less than 20 mm, as 

measured by a specially designed lower 

anchorage depth tool (ADT). The 

proposed ADT incorporates a hook-type 

CRS connector (see figure 3). The 20 

mm distance is marked on the tool. In 

a compliance test, the tool would be 

attached to a lower anchorage. The 

NPRM proposed that the 20 mm mark 

would have to be visible from a vertical 

longitudinal plane passing through the 

center of the bar, along a line making an 

upward 30-degree angle with a 

horizontal plane, without the technician 

manipulating the seat cushions in any 

way. 

The Alliance explained that the 

current requirements for FMVSS No. 

225 are based on the visibility of the 

lower anchorages around the soft trim 

and that the current FMVSS No. 225 

does not place the vehicle development 

process at risk as the standard gives 

manufacturers the option to certify the 

vehicles by adding seat cover markings 

if the lower anchorage is not visible. 

The Alliance stated anchorage depth in 

the current regulation is defined relative 

to a reference point, ‘‘Z’’ on the child 

restraint fixture (CRF), and the 

rearward-most location is defined in 


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ANCHORAGE. BAA 

Figure 3. Proposed Anchorage Depth Tool (ADT) (left) and Top View (right) 
1298 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

Section 9.2.2(a) as: ‘‘Not more than 70 

mm behind the corresponding point Z 

of the CRF, measured parallel to the 

bottom surface of the CRF and in a 

vertical longitudinal plane, while the 

CRF is pressed against the seatback by 

the rearward application of a horizontal 

force of 100 N at point A on the CRF’’ 

and that section S9.2.2(b) requires that 

the anchorage be located ‘‘Not less than 

120 mm behind the vehicle seating 

reference point.’’ The Alliance 

explained that these two requirements 

‘‘in essence’’ create the fore/aft ‘‘zone’’ 

for anchorage placement with respect to 

the seating reference point and the 

positioned CRF. The Alliance stated that 

during initial design of a vehicle, a 

virtual CRF is placed on the nominal 

seat to define the maximum anchorage 

depth and that this process locates the 

anchorages relative to defined hard 

points and ensures that the final 

anchorage location will be compliant to 

the regulation. The Alliance added that 

the application force of 100 N allows for 

the variation of foam and trim in a 

production vehicle. 

Difficulty Meeting the Current Lower 

Anchorage Location Requirements and 

the Proposed Anchorage Depth 

Requirement 

The Alliance explained that with 

certain current vehicle and seat designs, 

it is challenging to balance the 

maximum distance that the anchorage 

can be from the Z-point on the CRF with 

the 120-mm minimum distance the 

anchorage can be from the seating 

reference point (SgRP). The Alliance 

added that it may be difficult to meet 

the proposed lower anchorage depth 

requirements without violating the 

minimum distance the anchorage can be 

located from SgRP (S9.2.2(b)). The 

Alliance questioned the agency’s 

conclusion that because the proposed 

anchorage depth specifies an anchorage 

must be less than 20 mm deep into the 

seat bight, lower anchorages will be able 

to meet the proposed requirement 

without conflicting with S9.2.2(b). The 

Alliance disagreed with NHTSA’s 

conclusion, stating that (1) it does not 

consider the trim surface variation 

described above, and (2) it assumes all 

lower anchorages are located at the 

bight line, which is often not the case 

in vehicles with high bight lines. 

Difficulties in the Design Process for 

Ensuring Compliance With the 

Proposed Lower Anchorage 

Requirements 

The Alliance and FCA explained that 

the seat development process begins 

with virtual modeling tools used to 

establish the Vehicle Occupant Package 

(VOP) ‘‘hard points,’’ such as h-point, 

torso angle, seat belt anchorage 

locations, seat structure dimensions, 

etc., as well as the location of the lower 

anchorages. The Alliance and FCA 

added that these VOP ‘‘hard points’’ are 

established to ensure the final vehicle 

package will conform to all regulatory 

requirements while supporting 

customer-driven objectives such as 

comfort, seat adjustment forces, etc., for 

the seat design. 

The Alliance and FCA added that the 

production seat contour cannot be 

developed exclusively in the virtual 

design space and that design models 

cannot adequately capture the complex 

interaction of foam and trim tension, 

folding actuation clearance, and comfort 

requirements. The Alliance noted that 

in the typical vehicle development 

process, the seat trim outline (STO) 

begins in the CAD design space and 

then matures through several phases of 

physical properties to allow incremental 

evaluation of the VOP dimensions, 

occupant comfort, seat folding/adjusting 

efforts, and overall appearance. 

FCA explained that early seat 

development properties are built using 

skived foam (a foam cut from a solid 

block of foam) and that while these 

properties allow early evaluations of 

customer driven factors such as seat 

comfort, they are only directionally 

representative of final seat designs. FCA 

added that this is because skived foam 

does not have the same force/ 

displacement properties of production 

cast foam and that production foam is 

produced using a molding process that 

results in a ‘‘skin’’ at the surface of the 

foam and a variable density and 

stiffness that cannot be mimicked by 

skived foam (which has a constant 

density and stiffness). As a result, FCA 

explained it cannot accurately predict 

child seat installation efforts with the 

accuracy and confidence necessary for 

regulatory compliance. 

The Alliance and FCA stated that the 

virtual seat design process lacks the 

material properties necessary to predict 

lower anchorage attachment force with 

the accuracy necessary to guarantee 

regulatory compliance and that vehicle 

manufacturers will run the risk of late 

changes to the product design that will 

significantly increase design, 

manufacturing, and testing costs. 

The Alliance and FCA recommended 

that the agency investigate alternatives 

to those in the proposal, including 

dimensional reference from a CRF, to 

determine a more objective method of 

measurement that will accomplish the 

associated ‘‘ease-of-use’’ goal. FCA 

stated this approach will accomplish the 

goal of relocating anchorages closer to 

the seat bight, while still using proven 

design and compliance measurement 

processes. 

FCA stated that while it supports the 

overall goal of increasing the ‘‘ease-ofuse’’ of child restraint systems for 

caregivers, the proposed requirements 

and test methods are too dependent on 

‘‘soft’’ seat features like trim and foam. 

Similarly, the Alliance stated that the 

proposed method is overly sensitive to 

foam stiffness and the production 

variability between trim surface and the 

lower anchorages could exceed 20 mm. 

Ford stated it does not agree that seat 

design changes needed to meet the 

proposed lower anchorage requirements 

can be accomplished through steps such 

as cutting larger open areas in the seat 

foam surrounding the lower anchorage 

bars, as stated by NHTSA in the NPRM. 

Ford explained that the manufacturing 

process for seat cushions doesn’t 

typically involve secondary cutting 

operations. Ford also stated that design 

changes to meet the proposed 

requirements would require 

modifications to foam tooling. Ford 

explained these modifications could 

require inserts and separate 

compartments in the tool to locally 

revise the density of the foam and that 

any local voids in the cushion or 

seatback to provide clearance to 

anchorages would require a more laborintensive process to sew trim covers to 

achieve acceptable appearance and 

craftsmanship. Ford also explained that 

since the system characteristics are 

evaluated after the seat is built, the 

design process will be iterative, and 

won’t be fully understood until it 

fabricates the assessment tools and 

conducts evaluations of existing 

vehicles. 

Ford stated that, at minimum, the 

proposed requirements would require 

seat cushion, back foam, and trim 

changes to locally modify the foam 

density in the area of the lower 

anchorages. Ford added that lower 

anchorage bars in some vehicles may 

require modification so that the 

anchorages extend further forward invehicle. 

Subjectivity Reading Angle and ADT 

Angle During Measurement 

FCA expressed concerns that the 

angle of the line of sight for measuring 

the lower anchorage depth using the 

ADT can vary due to the parallax effect 

and therefore the lower anchorage depth 

measurement is user-dependent and 

lacks objectivity. Similarly, GM 

explained that the ADT measurements 

are subjective in some cases, such as 

when overlapping trim opening is 


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43Shown on figure 8 of GM’s submitted 

comments in Docket No. NHTSA–2014–0123–0056. 

44Ex parte memo for September 22, 2015, meeting 

with FCA. See docket NHTSA–2014–0123–0052 

and NHTSA–2014–0123–0053 in 

www.regulations.gov. 

45Ex parte memo for November 23, 2015, meeting 

with GM. See docket NHTSA–2014–0123–0056 in 

www.regulations.gov/. 

46 In June 2015, IIHS released its rating protocol 

along with tools to assess the usability of the lower 

anchorages with similar requirements. 

47 Detailed documentation of these changes can 

be found in the technical report: Louden, A.E., 

Wietholter, K., & Pruitt, C.E. (2022, May). 

Evaluation of LATCH Usability Tools Update 

(Report No. DOT HS 813 229). National Highway 

Traffic Safety Administration. This report will be 

available in this final rule’s docket. 

48 IIHS developed a tool that included a depth 

measurement gauge within the AFT. 

49NHTSA evaluated the IIHS depth tool method 

that is embedded in IIHS’s attachment force tool; 

however, results showed that the readings using 

this tool were different from the proposed tool, so 

NHTSA did not continue to use IIHS’s tool for 

depth measurements. Details can be found in the 

report: Louden, A.E., Wietholter, K., & Pruitt, C.E. 

(2022, May). Evaluation of LATCH Usability Tools 

Update (Report No. DOT HS 813 229). National 

Highway Traffic Safety Administration. This report 

will be available in this final rule’s docket. 

50 Klinich, K.D., Manary, M.A., Boyle, K., Malik, 

L., Bowman, P., Flannagan, C.A., ‘‘Evaluation of 

Repeatability and Reproducibility of Proposed 

Tools to Assess Lower Anchor Usability’’ UMTRI– 

2018–4, July 2018. This report will be docketed 

with the final rule. 

51This analysis is available in the technical 

report: Klinich, K.D., Manary, M.A., Boyle, K., 

Malik, L., Bowman, P., Flannagan, C.A., 

‘‘Evaluation of Repeatability and Reproducibility of 

Proposed Tools to Assess Lower Anchor Usability’’ 

UMTRI–2018–4, July 2018. 

present.43 GM requested clarification of 

the procedure regarding trim covering or 

surrounding trim being displaced by the 

tool and the angle of the tool during 

determination of the depth 

measurement. The Alliance stated there 

were differences between the UMTRI 

LATCH Usability study and the NPRM 

ADT measurements. The Alliance noted 

that the UMTRI Study specified no 

tension on the hook, which implies that 

the ADT will lie on the seat cushion, 

while the Vehicle Research and Test 

Center (VRTC) study was kept 

approximately parallel with the seat 

cushion. The Alliance added that 

S9.2.2(a) did not specify any tension to 

be maintained in the ADT, so it is 

implied that the tool would lie on the 

seat cushion when making the 

measurement. GM recommended that 

the test procedure require that the tool 

be kept parallel to seat cushion when 

reading the depth measurement. 

Repeatability 

FCA expressed concern regarding the 

tool’s R&R during two different ex parte 

meetings with NHTSA.44 During the 

September 21, 2015, meeting, FCA 

presented two R&R studies showing the 

measurements with the force and 

clearance angle tools had poor 

repeatability and reproducibility. FCA 

recommended NHTSA conduct its own 

R&R study and harmonize tools with 

IIHS if possible. GM also presented 

results from a limited study of gauge 

repeatability with the proposed tools 

during a November 23, 2015, ex parte 

meeting.45 GM explained that the gauge 

repeatability study showed that further 

refinement of the proposed tools was 

required to meet industry guidelines of 

repeatability. 

b. Post-NPRM Research 

After careful consideration of 

comments received in response to the 

NPRM, NHTSA carried out a study to 

assess whether and how the tools 

proposed in the NPRM could be 

modified. Specifically, some 

commenters expressed concerns about 

the R&R of the tools and the subjectivity 

of some measurements. Some 

commenters suggested improvements to 

the tools and the tools’ instrumentation 

to have more repeatable measurements 

and better usability. Finally, some 

commenters also stated that NHTSA 

should harmonize or adopt the tools and 

procedures being used by the IIHS for 

consistency of evaluation on the lower 

anchorage attachments.46

During the course of the study, 

NHTSA reviewed IIHS’s rating protocols 

and tools to consider any beneficial 

features provided by the tools. NHTSA 

proceeded to implement tool 

improvements to address the 

commenters concerns by updating the 

AFT and its instrumentation via an 

iterative process.47 Specifically, NHTSA 

added features to the AFT, similar to the 

IIHS rating protocol,48 by including a 

guide rod to guide the tool towards the 

anchorage. Other modifications 

included updating instrumentation to 

digitally record the angle during the 

test, adding an actuator allowing for a 

steady rate of force application, and 

adding a support leg to stabilize the tool 

and maintain the approach angle during 

the attachment force measurements. 

These modifications were expected to 

produce more consistent results by 

resolving the issue of aligning the tool 

with hidden anchorages, reducing the 

inconsistencies from off-axis loading 

and having more consistent readings 

with new instrumentation. The 

repeatability study results are discussed 

in greater detail in the GR&R Study 

portion of this section below. 

For the updated CAT, NHTSA added 

a pulley bridge (with adjustable feet to 

make it level) to apply a 67 N (15 lbf) 

force vertically to remove the difficulty 

of applying the constant load manually. 

NHTSA also added digital 

instrumentation that allowed timehistory data to be recorded. Further, 

NHTSA replaced the rotary 

potentiometer several commenters 

expressed concerns about with an 

analog position sensor to collect the 

angle data more reliably. To improve 

durability, the jaw of the tool was also 

reinforced with steel plates and the 

latch tooth was updated to be 

refabricated completely out of steel. 

For the depth measurement 49 NHTSA 

modified the ADT through the addition 

of a sliding view bar to create a more 

consistent view angle and an additional 

depth gauge measurement device to 

provide a numerical value for the depth, 

rather than using color markings for the 

20 mm depth reading. 

GR&R Study 

Following its initial study and tool 

modifications, NHTSA considered 

comments expressing concerns over tool 

repeatability and reproducibility. In 

response to comments that NHTSA 

should use the industry’s standard 

gauge repeatability and reproducibility 

(GR&R) methodology to evaluate the 

measurement tools’ R&R, NHTSA 

conducted a GR&R study with the 

improved tools to determine if the 

updated tools provided repeatable and 

reproducible measurements. 

NHTSA contracted UMTRI to evaluate 

the NHTSA-improved tools. The 

evaluation sought to identify any further 

improvements that could be made to the 

tools and to do a GR&R assessment 

study with the modified tools. NHTSA 

also required UMTRI to perform a 

statistical analysis to quantify the 

usability of the toolsets according to 

industry standards to address 

manufacturers’ NPRM comments.50

UMTRI conducted the GR&R study in 

two phases to evaluate the effects of 

different operators, tools, and vehicles. 

Each phase used 10 different vehicle 

models for the modified tool 

evaluations. UMTRI picked the first 

phase’s vehicles based on the 214 

vehicles used for the IIHS CRAS study. 

Phase one vehicles were selected to 

allow evaluation of the tools and 

procedures across a range of different 

seat styles found in the MY 2016 vehicle 

fleet.51 For phase two, UMTRI again 

based vehicle selection on the IIHS 

CRAS study vehicles, with an emphasis 

on finding vehicles with lower 

anchorages in the second-row center 

(2C) seating position or vehicles with a 

third row of seats. UMTRI also looked 

at the data from phase one to identify 


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1300 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

52For details on the vehicles and measurements 

see Klinich et al (2018). 

53This reference manual, developed by the 

vehicle industry, contains guidelines for assessing 

the quality of a measurement system. Down, M., 

Czubak, F., Gruska, G., Stahley, S., Benham, D. 

(2010) Measurement Systems Analysis Reference 

Manual, Fourth Edition. Chrysler Group LLC, Ford 

Motor Company, General Motors Corporation. 

http://www.rubymetrology.com/add_help_doc/ 

MSA_Reference_Manual_4th_Edition.pdf. 

54 Klinich et.al. 2018. 

55See Anchorage Depth Tool Decision below 

(section V.d.2), where NHTSA explains why the 

anchorage depth threshold changed from 20 mm to 

25 mm. 

56 Greenwell, N.K. (2015, May). Results of the 

national child restraint use special study. (Report 

No. DOT HS 812 142). Washington, DC: National 

Highway Traffic Safety Administration. 

57 GR&R is the process used to evaluate a gauging 

instrument’s accuracy by ensuring its 

measurements are repeatable and reproducible. The 

process includes taking a series of measurements to 

certify that the output is the same value as the 

input, and that the same measurements are obtained 

under the same operating conditions over a set 

duration. See https://asq.org/quality-resources/ 

gage-repeatability. 

58 Klinich, K., Manary, M.A., Boyle, K., Malik L.J., 

Bowman, P., Flannagan, C.A.’’ Evaluation of 

Repeatability and Reproducibility of Proposed 

Tools to Assess Lower Anchor Usability’’ July 2018. 

Report will be docketed with this final rule. 

59 Klinich et al., ‘‘LATCH Usability in Vehicles,’’ 

UMTRI–2012–7, April 2012. Link: https://

deepblue.lib.umich.edu/handle/2027.42/90856. 

60See www.regulations.gov/document/NHTSA2014-0123-0001. 

61 Identified as CAT V2 in technical reports. 

measures of interest for phase two, such 

as pick-up trucks and coupe vehicles. In 

selecting vehicles for the study, UMTRI 

tried to maximize variation among 

manufacturers, while also considering 

the availability to rent such vehicles for 

testing. UMTRI’s GR&R study 52 found 

that for the clearance angle 

measurement 92 percent of variance is 

attributable to the vehicle (part) 

variability and only 8.4 percent is 

attributable to system variability 

(combined variability of the tools, 

operator, and repeat measurements). For 

the depth measurement UMTRI found 

that 93 percent of the variance is 

attributed to the vehicle (part) 

variability and only 7 percent to the 

system variability. For the force 

measurement, UMTRI found that 67 

percent of the variance comes from 

vehicle (part) variation and 33 percent 

comes from the system variability. 

According to the Measurement Systems 

Analysis Reference Manual (MSA),53 a 

system variation in the measurement of 

10 percent or less is considered 

acceptable R&R of the measurement, 

while a system measurement variability 

of 30 percent or more is considered 

unacceptable. The results of UMTRI’s 

GR&R Study demonstrate that the 

anchorage depth and clearance angle 

measurements obtained via the updated 

ADT and CAT have good R&R, but that 

the anchorage force measurement with 

the AFT V2 does not. Further details of 

the GR&R analysis are available in the 

UMTRI GR&R study report.54

c. Summary of Decision on Assessing 

Usability of Lower Anchorages 

This final rule adopts the updated 

lower anchorage depth and clearance 

angle tools and requirements, but not 

the attachment force requirement. These 

adopted requirements will ensure that 

lower anchorages on vehicles subject to 

this rule have sufficient clearance 

around each lower anchorage, and that 

the lower anchorages are within 25 mm 

of the outer surface of the seat bight 

(anchorage depth).55 Lower anchorages 

meeting these requirements will be 

easier to use, as shown by the UMTRI 

and IIHS data. 

The LATCH Usability study found 

these ease-of-use specifications correlate 

with correct child restraint installations. 

National Child Restraint Use Special 

Study (NCRUSS) 56 data showed that a 

loose CRS installation comprises one of 

the five most significant mistakes 

consumers make when installing child 

restraints. Loose CRS installations can 

result in greater movement of a child 

and their CRS during a crash, increasing 

the risk for injury and higher injury 

severity due to possible contact with 

vehicle interior structures. CRASs 

designed to be easier to properly use 

will increase correct (tight) CRS 

installations, making children safer in a 

crash. 

The NPRM proposed clearance angle, 

attachment force, and anchorage depth 

specifications. This final rule is only 

adopting requirements and 

measurement tools for the clearance 

angle and anchorage depth. The agency 

evaluated a series of changes to the 

attachment force tool to improve its 

R&R. However, the GR&R 57 study found 

that measurements from the attachment 

force tool lacked acceptable level of R&R 

needed for adopting into the standard.58

NHTSA does not believe further 

improvements to the attachment force 

tool will be enough to achieve a 

sufficient R&R. 

UMTRI’s LATCH Usability study 59

identified three vehicle hardware 

characteristics serving as predictors for 

correct CRS use, analyzing the 

predicting factors of force and depth 

separately and together. Depth and 

attachment force when analyzed 

separately showed each were highly 

significant predictors of correct lower 

anchors use. But when these vehicle 

characteristics were analyzed together, 

force became marginally significant 

while depth remained a highly 

significant predictor. UMTRI concluded 

that while these results do not guarantee 

a causal relationship between depth and 

correct installations, the results do 

indicate that depth is a better predictor 

of correct installations than force. 

Although Alliance and FCA 

commented that only the anchorage 

depth requirement was warranted, 

NHTSA disagrees. UMTRI’s LATCH 

Usability in Vehicles Study analyzed 

depth and clearance angle. Study results 

concluded that separately they each 

were highly significant predictors of 

correct use of lower anchors. When 

analyzed together, to the extent there is 

unique variance attributable to depth 

and clearance separately, depth and 

clearance angle both became marginally 

significant. This indicates that both are 

equally predictive of correct 

installation. 

Because the study could not estimate 

the contribution of each feature, NHTSA 

cannot accurately calculate the effect of 

not having the attachment force as a 

requirement. The data does indicate that 

by having clearance angle and depth 

requirements, correct CRS usage will 

improve. 

d. Detailed Agency Decisions Regarding 

the Tools and Performance Criteria 

1. Clearance Angle Tool and Minimum 

Allowable Clearance Angle 

NHTSA understands that some 

vehicles will need redesign to meet both 

requirements. But as presented in figure 

9 of the 2015 NPRM,60 the depth 

requirement is feasible in many vehicles 

without making any design changes to 

meet the S9.2.2(b) requirements. 

Following careful consideration of 

comments received and further studies 

described above, NHTSA has modified 

the NPRM’s proposed clearance angle 

tool (CAT) to address several concerns 

raised by commenters. The final design 

of the CAT now includes a pulley bridge 

to apply a consistent vertical force of 67 

N (15 lb) to address commenters’ 

concerns regarding the difficulty in 

applying the force in the proposed CAT. 

Further, although the proposed CAT 

had digital instrumentation allowing for 

the recording of time-history data, based 

on comment feedback, NHTSA has 

implemented new instrumentation to 

improve measurement repeatability, 

including an analog position sensor and 

an Interface S-Type load cell. 

UMTRI’s GR&R study found that the 

measurement variability of the updated 

CAT 61 system was less than 10 percent 

of the total measurement variability, 

confirming that the updated CAT 


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62For full comments and associated figures see 

www.regulations.gov/comment/NHTSA-2014-0123- 

0049. 63 Docket No. NHTSA–2014–0123–0049. 

64 Identified as ADT V4 in technical reports. 

65UMTRI’s LATCH Usability study (2012) was 

not conducted with the precision tools such as the 

ADT included in this final rule. The UMTRI Study 

tools had some ambiguities regarding a consistent 

viewing angle to detect the change in color from the 

hook-type tool. The additional 5 mm is in the realm 

of depth reading variability from that study. 

measurements have sufficient R&R for 

regulatory purposes. 

Accordingly, this final rule 

incorporates the requirement of a 

minimum of 54-degrees clearance angle 

in FMVSS No. 225 when applying a 67 

N vertical load to the updated tool. 

Drawings of the final updated CAT 

design have been incorporated by 

reference into FMVSS No. 225. NHTSA 

has placed a copy of the drawings in the 

docket for this final rule. 

While supportive of a clearance angle 

requirement, Advocates argued that the 

proposed 54 degree minimum was too 

low. NHTSA selected the 54-degree 

clearance angle based on a 50 percent 

correct CRS use in UMTRI’s LATCH 

Usability study. Only 2 of the 98 

vehicles studied by UMTRI had a 

clearance angle above 75 degrees, which 

calls into question the feasibility of 

defining 75 degrees as a limit. The 

proposed values provide an 

improvement on correct installations 

and are not overly burdensome for 

manufacturers to meet. NHTSA also 

believes that vehicles will be well above 

the 54 degree clearance angle, as the 

standard will also require anchorages 

depths that typically result in higher 

clearance angles. Fifty-four of the 98 

vehicles in UMTRI’s study had 

clearance angles over 54 degrees 

(ranging 54–83 degrees), which will 

improve correct installations beyond the 

50 percent used to establish the 

threshold. 

In response to the Alliance’s request 

for clarification on whether the CAT 

measurements must be made 

independently or at both anchorages 

concurrently, the CAT measurements 

are to be done independently at each 

lower anchorage in the vehicle. Further, 

NHTSA does not agree with the 

Alliance’s suggestion that the weight of 

the tool needs to be subtracted from the 

total force applied to arrive at the 67 N 

requirements. With the tool 

modifications to the CAT, the 67 N will 

provide a constant load, and subtracting 

the force due to the weight of the tool 

would add unnecessary complexity to 

the system. 

NHTSA acknowledges comments 

made by MGA 62 on the proposed tools 

and technical drawings published with 

the NPRM. Specifically, MGA stated 

that ‘‘the spring pockets are 0.146’’ 

offset, which causes the spring to fall 

out during compression.’’ Based on this, 

MGA stated that it did the following: 

(1.) moved the pivot to spring pocket 

distance as follows: 4.970¥2.500 = 

2.470 (upper spring pocket); (2.) moved 

the pivot to spring pocket distance as 

follows: 3.216¥0.600 = 2.616 (lower 

spring pocket); (3.) moved the upper 

spring pocket forward 0.125’’ to align 

the upper and lower spring pocket more 

closely, and prevent the spring from 

falling out during compression. 

In addition to these changes, MGA 

pointed out that the load cell presented 

in NHTSA’s NPRM is not commercially 

available. As such, MGA replaced the 

load cell with an Interface SSM–AJ–100 

load cell. MGA explained the hardware 

to attach the load cell to the handle and 

ball and joint connection are Interface 

CLV–104 clevises. MGA also noted the 

female rod end is McMaster part 

number 60645K32, while the male rod 

end is unchanged. Finally, MGA 

redefined the clearance angle tool 

handle measurements to fit the Interface 

clevis CLV–104 that is used with the 

Interface SSM–AJ–100 load cell. 

In response to these comments, 

NHTSA has updated the drawings as 

follows: the dimension 4.97 inches in 

drawing DA609–001 (figure 9 in MGA 

comments) is corrected to 5.15 inches to 

eliminate the offset this dimension 

created with drawing DA609–003. 

However, NHTSA did not move the 

upper spring pocket forward 0.125 

inches as suggested by MGA because the 

spring was modified to a conical spring 

(in Drawing DA609–000), which 

prevents the spring from falling out 

during compression. The upper spring 

pocket was thus left in the same 

location as proposed. In response to 

comments on the load cell, NHTSA 

updated the drawings as follows for this 

final rule: the proposed load cell is 

changed to the S-Type load cell 

suggested by MGA, which is 

commercially available. However, 

suggested changes to the handle and 

attachments to the handle will not be 

implemented, as they are now moot as 

this part was removed and replaced 

with a pulley system. 

Finally, NHTSA acknowledges MGA’s 

request for clarification on certain 

inconsistent dimensions in two 

drawings, as seen in figures 17 and 18 

of MGA’s comments.63 In response to 

these comments, this final rule updates 

the drawings as follows: the material in 

Drawing DA609–005 is changed from 

having a material PL 1′′ x 13⁄16′′ x 17⁄8′′ 

to PL 1′′ x 13⁄16′′ x 5′′ to correct the 

inconsistent dimensions in the drawing. 

Further, drawing DA609–006 is 

removed as the mount in this drawing 

is no longer needed. 

2. Anchorage Depth Tool and Maximum 

Allowable Anchorage Depth 

NHTSA acknowledges that several 

commenters, including GM and FCA, 

expressed concerns about the 

repeatability of the ADT tool and the 

subjectivity of the viewing angle in 

determining whether the measurement 

was 20 mm or less. After careful 

consideration this final rule’s updated 

ADT64 addresses concerns over viewing 

angle subjectivity through the addition 

of a view bar and zero-strip that 

translate the viewing angle into a 

physical measurement. In support of 

this decision, UMTRI’s GR&R study 

found that the ADT measurement 

variability of the updated system was 

less than 10 percent of the total 

measurement variability (specifically, 

93 percent of the variance in the depth 

measurements is attributed to vehicle 

variation and only 7 percent to the 

system variability), confirming that the 

updated ADT measurements have 

sufficient R&R for regulatory purpose. 

This final rule is also increasing the 

NPRM’s proposed 20 mm limit to 25 

mm. As noted earlier, since the study 

vehicles were selected based on their 

different characteristics and not as a 

randomized selection, the agency’s 

analysis does not fully evaluate the 

variability across vehicles. There could 

be some anchorage depth measurement 

variability in some seat designs. Further, 

the GR&R study by UMTRI considered 

depth measurements rounded to the 

nearest quarter cm. In acknowledgment 

of these limitations in the GR&R 

analysis, NHTSA is specifying that the 

anchorage depth be 25 mm or less, 

rather than the 20 mm proposed in the 

NPRM. As such, measurement by the 

finalized ADT will account for 

measurement and manufacturing 

variability. Expanding the depth 

requirement to 25 mm will still result in 

improved usability and a higher number 

of correct installations.65

NHTSA did not consider lowering the 

anchorage depth to less than 20 mm, 

which would be a more stringent 

threshold than that proposed in the 

NPRM. In response to the Alliance’s 

comment asking why a 4 cm anchorage 

depth was not proposed, as that depth 

also showed correct installations in 

UMTRI’s LATCH Usability study, 

NHTSA points out that the UMTRI 

LATCH Usability study found that study 


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66The UMTRI ‘‘LATCH Usability’’ study showed 

correct use of 85.9 percent, 50.7 percent and 43.1 

percent for lower anchorage depths of 0–2 cm, 2– 

4 cm and 4–6cm respectively. We expect lower 

anchorages with depths between 2–4 cm that are 

closer to 2 cm would have higher correct use and 

those closer to 4 cm would have lower correct use. 

67 Klinich et al., ‘‘LATCH Usability in Vehicles,’’ 

UMTRI–2012–7, April 2012. Link: https://

deepblue.lib.umich.edu/handle/2027.42/90856. 

68 Down M, Czubak F, Gruska G, Stahley S, 

Benham D. (2010) Measurement Systems Analysis 

Reference Manual, Fourth Edition. Chrysler Group 

LLC, Ford Motor Company, General Motors 

Corporation. Link: http://www.rubymetrology.com/ 

add_help_doc/MSA_Reference_Manual_4th_

Edition.pdf. 

69 Klinich et al., ‘‘LATCH Usability in Vehicles,’’ 

UMTRI–2012–7, April 2012. Link: https://

deepblue.lib.umich.edu/handle/2027.42/90856. 

volunteers correctly installed CRSs 50.7 

percent of the time when using 

anchorages with depths 2 to 4 cm,66 but 

that anchorage depths of 0 to 2 cm 

showed a more pronounced 

improvement to 85.9 percent correct 

CRS installation. As a 35 percent 

increase in the number of correct CRSs 

installed is a significant increase in the 

crash safety protections provided to 

young children, the Agency declines to 

consider a 4 cm anchorage depth for this 

final rule. In response to the Alliance’s 

suggestion to better define the 

tensioning and angle placement of the 

ADT during the procedure, as the 

updated ADT is pulled taut so that the 

anchorage bar engages the tool, a need 

to define the tension does not exist, as 

the required tool is rigid. 

NHTSA is rejecting a comment 

requesting the removal of the 

prohibition in FMVSS No. 225 on 

stowable lower anchorage bars, as lower 

anchorages should be readily available 

for use and no further steps should be 

necessary (other than removing a lower 

anchorage specific cover) to access and 

use them. 

NHTSA agrees with GM’s 

recommendation to position the ADT at 

an angle parallel to the seat cushion to 

make measurements and has revised the 

NPRM’s proposed procedure to specify 

that the ADT will be positioned at an 

angle parallel to the seat cushion. The 

test procedure will indicate how to 

measure the seat cushion angle (using a 

2 ft level and an inclinometer) and how 

to position the ADT to reach this angle 

(use of shims if necessary). In response 

to expressed concerns over the 

measuring tool potentially displacing 

the trim covering or surrounding trim 

being displaced by the tool, NHTSA 

notes that this final rule’s anchorage 

depth measurement procedure allows 

for clear depth measurement via the 

taping away from anchorages (with 

masking tape) such things as coverings, 

flaps, or other vehicle parts. In relation 

to concern over trim coverings, 

including slits where the fabric or 

leather is too stiff to be taped, there 

should be minimal manipulation of the 

slit to introduce and hook the ADT in 

the anchorage and pull it back. The ADT 

may push away some of the fabric or 

leather when it is engaged to the lower 

anchorage. The depth will be measured 

where the viewing strip comes in 

contact with the vehicle seat (which 

includes the fabric or leather). Since the 

vehicle is prepared before the test 

measurement by marking the vehicle 

seat with a line perpendicular to the 

anchorage center, the tool can be easily 

directed to the anchorage. 

In response to commenters that 

suggested developing a depth measure 

based on a hard point given the 

difficulty in designing and controlling 

the variance of the foam/trim elements 

during the design process, NHTSA 

respectfully disagrees with this 

suggestion. The LATCH Usability 

study 67 found that anchorages 

positioned less than 20 mm from the 

seat bight result in more correct 

installations. Further, one noted issue 

consumers experience when installing 

CRSs with deep anchorages is 

difficulties with the foam of the seat 

and/or the fabric/leather surrounding 

the anchorage. As anchor depth 

measurement from a hard point 

measurement does not take the 

interactions of the seat foam and fabric 

into consideration, a depth 

measurement based on a seat hard point 

would not necessarily improve ease-ofuse and correct installations. NHTSA 

does acknowledge that there may be 

greater variability in foam and different 

trim levels than those considered in the 

UMTRI GR&R analysis. To account for 

any potential measurement or 

manufacturing variability this final rule 

specifies an anchorage depth of no more 

than 25 mm, as opposed to the proposed 

20 mm, to account for measurement and 

manufacturing variability. 

Several commenters expressed 

concerns over the costs of required 

tooling changes to meet the depth 

requirements of this final rule. NHTSA 

acknowledges that tooling changes for 

existing production vehicles can be very 

costly and are better accommodated 

during the early design stage of a 

vehicle’s renewal cycle to minimize any 

potential costs. Accordingly, the agency 

finds good cause to provide more lead 

time and a phase-in for manufacturers to 

account for different trims and the 

possibility of tooling changes to meet 

the depth requirements required by this 

final rule. As such, this final rule is 

providing a longer lead time than that 

proposed in the NPRM, with a phase-in 

schedule (see Lead Time Section). 

NHTSA is permitting optional early 

compliance with this final rule’s 

requirements. 

3. Attachment Force Tool 

Following careful consideration of 

comments received and additional 

testing, NHTSA has decided not to 

adopt the NPRM’s proposed attachment 

force requirements into FMVSS No. 225. 

Following publication of the NPRM, 

NHTSA attempted to improve the R&R 

of the AFT. However, UMTRI’s GR&R 

study, which used the improved AFT, 

found that 67 percent of depth 

measurement variance came from 

vehicle (part) variation and 33 percent 

came from system variability (variability 

attributed to the tools, operators, and 

repeated measurements). The 

Measurement Systems Analysis 

Reference Manual (MSA) 68 document, 

followed by the vehicle industry, 

indicates that when evaluating a test 

procedure, it is acceptable if the 

system’s percentage variation is less 

than 10%. This means the improved 

AFT failed to reach an acceptable R&R 

for adoption into the standard. NHTSA 

does not believe further improvements 

to the AFT would achieve sufficient 

repeatable and reproducible 

measurements for regulatory purposes. 

Further, although Ford suggested using 

the average of several measurement 

trials using the AFT as the criteria for 

anchorage attachment force, NHTSA 

found R&R was not sufficiently 

improved by considering the average of 

five measurement trials for some vehicle 

seats. As NHTSA has determined the 

adoption of the AFT into FMVSS No. 

225 is not feasible, this final rule does 

not address additional comments 

received suggesting improvements to 

the tool. 

Despite the decision not to include an 

attachment force criterion into FMVSS 

No. 225, the remaining requirements of 

this final rule will improve the ease-ofuse of the lower anchorages. UMTRI’s 

study 69 identified the characteristics of 

attachment force, clearance angle, and 

attachment depth as predictors for 

correct CRS use, and then modeled the 

predicting factors of force and depth 

both separately and together. Analyzed 

separately, depth and attachment force 

were highly significant predictors of the 

correct use of lower anchors. Analyzed 

together, depth remained a highly 

significant predictor, while attachment 

force was only a marginally significant 


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70 64 FR 10786. 

71The NPRM also proposed amending FMVSS 

No. 213 to limit the length of the CRS tether 

hardware assembly (which consists of a tether hook 

and hardware to tighten and loosen the tether strap) 

to 165 mm (6.5 in) so that the tightening mechanism 

can be easily used in the clearance space around a 

tether anchorage. 

72 Dr. Baer is a pediatrician, advocate and 

nationally certified child passenger safety instructor 

best known as The Car Seat Lady. 

73Safe Kids is a network of organizations working 

to prevent unintentional childhood injury, the 

leading cause of death and disability for children 

ages 1 to 14. 

74The shelf behind the rear seat in a sedan. 

75Backlight is the rear windshield or back 

window glass in a vehicle. 

predictor. As such, UMTRI concluded 

that although these results do not 

guarantee a causal relationship between 

depth and correct installations, they do 

indicate that depth is a somewhat better 

predictor of correct CRS installations 

than attachment force. This final rule’s 

depth requirements ensure that the 

lower anchorages will be placed in a 

more forward position, making them 

more likely to avoid foam material and 

structures and potentially resulting in 

decreased force needed to attach the 

lower anchorage. Further, this final 

rule’s required clearance angle will 

ensure no material or structure will 

prevent placement of the lower 

anchorage attachment, which may also 

result in less required force to attach the 

lower anchorage. 

VI. Improving the Ease of Using the 

Tether Anchorage 

FMVSS No. 225 currently requires 

vehicle manufacturers to equip vehicles 

with a tether anchorage at three rear 

designated seating positions (two of 

these positions are also required to be 

equipped with lower anchorages). 

Tether anchorages must be in a 

specified zone accessible without the 

need for any tools other than a 

screwdriver or coin. Tether anchorages 

must be easy to use, as they are the 

primary factor behind the estimated 36– 

50 lives saved a year following 

NHTSA’s adoption of FMVSS No. 225.70

To further improve the usability of the 

tether anchorage by making it easier for 

customers to recognize and access, the 

NPRM proposed the following 

requirements: 

• Reduce the zone in which a tether 

anchorage must be located to prevent 

tether anchorages from being placed 

deep under a vehicle seat. 

• As some tether anchorages are too 

close to a structure, such as a head 

restraint, specify a minimum 165 mm 

(6.5 in) distance from a specified 

reference point on the vehicle seat to the 

tether anchorage to allow for the 

tightening of the tether strap. This 

requirement will ensure that adequate 

clearance is provided to tighten the 

tether strap.71

• Tether anchorages must be 

accessible without the need for any 

tools other than a screwdriver or coin, 

and without folding the seatback or 

removing carpet or other vehicle 

components. The tether anchorage 

could be covered with a cap, flap, or 

cover, provided that the cap, flap, or 

cover is specifically designed to be 

opened, moved aside, or to otherwise 

give access to the anchorage without the 

use of any tools and is labeled with a 

specific symbol indicting the presence 

of the tether anchorage underneath. 

• Requiring a standardized rigid bar 

so consumers could more easily 

recognize and find it, as currently some 

tether anchorages are made from flexible 

webbing. 

• Standardizing the tether anchorage 

marking by requiring that it match a 

marking on the child restraint system 

tether and be placed within a specified 

distance from the anchorage. 

General Comments 

Commenters almost unanimously 

supported improving the ease-of-use of 

tether anchorages but differed in their 

views on specific NPRM proposals. 

Overall, child restraint manufacturers 

and private individuals supported the 

proposed improvements to the ease-ofuse of the tether anchorage. SRN and an 

individual, Dr. Baer,72 agreed on the 

standardization, accessibility, and 

clearance (165 mm distance to tether 

anchor) proposals to improve tether use. 

However, Dr. Baer disagreed with 

allowing tether anchorage covers, 

stating that they hide a safety feature. 

SRN and Dr. Baer expressed concerns 

over some tether anchorage designs 

concealed by other vehicle structures, 

making them difficult to access. IIHS 

also supported reducing the allowable 

zone for tether anchorages to better align 

allowable locations with the locations 

parents expect to find tether anchorages. 

Safe Kids 73 expressed support for a 

harmonized, consistent, and easily 

understood way to identify and use the 

CRAS. 

In contrast, the Alliance and several 

vehicle manufacturers objected to the 

proposed requirements to reduce the 

zone where top tethers could be located, 

including specifically to the proposed 

tether anchorage location on the 

package shelf 74 behind second-row 

seats in vehicles such as sedans. The 

Alliance stated that many passenger cars 

that have the tether anchorages 

conveniently located in the package 

shelf behind the seat will not meet the 

proposed 165 mm minimum wrap 

around distance. The Alliance 

explained that current design locations 

that would be precluded by the 

proposed requirements do, in fact, 

enable effective attachment since the 

path over a fixed head restraint or under 

an adjustable head restraint provides 

additional wraparound distance to 

tighten the tether strap. Several vehicle 

manufacturers stated that the proposed 

requirement would force the relocation 

of tether anchorages rearward in the 

vehicle, resulting in less hand clearance 

to the vehicle backlight 75 window for 

manipulating the tether hook. Vehicle 

manufacturers also expressed concern 

over costly repackaging of components 

such as speaker assemblies that 

currently occupy the space where the 

tether anchorage would have to be 

placed. Some commenters urged 

NHTSA to use a point farther forward in 

the vehicle’s seat than the proposed SB 

point, explaining the SB point is not a 

reference that can be found on all of 

their vehicles. 

The Alliance and several vehicle 

manufacturers sought clarification on 

some terms related to the reduced tether 

anchorage zone under the seat, and also 

commented on other proposed 

provisions for improving the ease-of-use 

of tether anchorages (e.g., accessing 

tether anchorages without tools, 

accessing tether anchorages without 

folding the seatback or removing carpet 

or other vehicle components, such as 

luggage compartment security covers, 

and using rigid bars in light trucks). 

Commenters also expressed concerns 

with the proposed requirements based 

on their implications and costs. Vehicle 

manufacturers generally commented 

that the proposed 3-year lead time is 

insufficient to account for necessary 

changes, and many asked for a phase-in 

of the requirements. 

a. Attaching to the Tether Anchorage 

Tether Anchorage Accessibility—Zone 

Under the Seat 

To promote accessible tether 

anchorages, current FMVSS No. 225 

requires that tether anchorages be 

located within the shaded zone shown 

in figures 3 through 7 of FMVSS No. 225 

for the designated seating position (DSP) 

where the anchorage is installed. In 

considering changes to FMVSS No. 225 

to further increase tether anchorage 

accessibility, the agency first evaluated 

vehicle fleet data to better understand 

where tether anchorages are currently 

located. The evaluation found that the 

most common tether anchorage 


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76 IIHS was the sole commenter that encouraged 

NHTSA to further reduce the allowable zone for 

tether anchorages to better align allowable locations 

with where parents expect to find tether 

anchorages. While NHTSA agrees a more reduced 

zone would place tether anchorages where 

consumers may be more likely to anticipate them, 

the agency must also consider other factors a 

vehicle manufacturer has to weigh when deciding 

the location of tether anchorages. Manufacturers 

consider factors such as strength of the structures, 

features that the manufacturer may design into seats 

such as pass through openings, seat back folding 

mechanisms that may cause the tether anchorages 

to be in the back of the seat, and other design 

considerations. Thus, NHTSA is not reducing the 

zones in this rulemaking. 

77This deep under the seat location is the 

forward-most edge of the area under the vehicle 

seat. The location is defined by the intersection of 

the torso line reference plane (defined by the 2016 

SAE J826 two-dimensional drafting template) and 

the floor pan. 

78 Vehicles with tether anchorages located deep 

under the seat where the seat must be folded to 

reach the anchorages are no longer manufactured, 

so this change in requirements will have little or no 

impact on current vehicle designs. However, the 

amendment is needed to prevent these designs from 

coming back into the fleet. 

79Figure 3 of Docket No. NHTSA–2014–0123– 

0027. 

80Ford’s illustrations can be found in figure 3 of 

Docket No. NHTSA–2014–0123–0026. 

81Alliance’s illustrations can be found on pages 

8–9 of Docket No. NHTSA2014–0123–0027. 

82Honda’s illustrations can be found on pages 3 

of Docket No. NHTSA2014–0123–0017. 

83The Alliance’s illustrations can be found on 

pages 9 of Docket No. NHTSA2014–0123–0027. 

locations are the seatback (41 percent), 

the package shelf (37 percent), the back 

wall of the occupant compartment (8 

percent), the roof (6 percent), the floor 

(4 percent), and under the seat (3 

percent). NHTSA contemplated the 

merits of designing the NPRM to 

considerably limit the zones in figures 

3 through 7, but decided against this 

approach following review of NHTSA’s 

test data. This data showed that the 

current allowable locations of tether 

anchorages do not increase the risk of 

injuries, as their performance and 

loading to the anchorages are very 

similar to tether anchorages that are 

centered and closer to the seat. Further, 

NHTSA acknowledges that vehicle 

manufacturers must consider many 

factors in deciding where to place a 

tether anchorage, including the strength 

of the structure to which the tether 

anchorage is affixed, the degree to 

which the tether anchorage—or the 

child restraint, when using the 

anchorage—interferes with ingress, 

egress, seating, and/or the comfort and 

safety of vehicle occupants. Due to these 

considerations, vehicle manufacturers 

sometimes install tether anchorages 

slightly off-center to a seating position, 

or on the roof, floor, or back wall. 

Recognizing there is merit in providing 

flexibility to manufacturers to balance 

where to locate the anchorages, the 

agency decided not to considerably 

narrow the zones in figures 3 through 

7.76 Instead, the NPRM sought to 

improve the ease of using tether 

anchorages via other means. 

First, the agency proposed to reduce 

the allowable zone under the seat, 

because the shaded zone shown in 

figures 3 through 7 encompasses a wide 

area that has resulted in some tether 

anchorages being located where 

consumers have had difficulty accessing 

them, such as deep under the seat where 

folding the seat is required to reach/ 

attach the tether anchorage.77 As such, 

NHTSA proposed to amend figures 3 

through 7 in the standard to disallow 

tether anchorages from being placed 

deep under the seat. Specifically, the 

agency proposed that the forwardmost 

edge of the allowable tether anchorage 

zone represented by the shaded area in 

figure 3 of the standard be moved 

rearward to a position defined by the 

intersection of the vehicle floor with a 

plane parallel to the torso line reference 

plane passing through the rearmost 

point of the bottom of the seat at its 

centerline.78

Comments Received 

Vehicle manufacturers generally 

disagreed with the proposal laid out in 

the NPRM. Global stated that for certain 

vehicle designs the bottom of the seat 

may be the most suitable location for the 

anchorages and requested that the 

agency permit continued use of the 

bottom of the seat for tether anchorages 

if the manufacturer includes appropriate 

markings on the seatback to alert 

consumers to the anchorage location. 

The Alliance argued the proposal to 

restrict the allowable tether zone under 

the seat may be appropriate for 

passenger cars with limited space under 

the seat, but it unnecessarily limits the 

location of the anchorage for mini-vans, 

vans and some SUVs. The Alliance 

provided figures in its comments 79

showing a full-size van rear seat with 

the upper tether anchorage located on 

the seat structure forward of the 

forward-most limit of the proposed zone 

and explained that the location provides 

a readily accessible upper anchorage 

point formed into the seat. The Alliance 

stated the proposed acceptable zone 

would require additional anchorage 

hardware that would need to be welded 

to the seat structure. The Alliance 

explained that because the current 

design is stamped into the existing seat 

structure, manufacturers can voluntarily 

provide additional anchorages at very 

low cost (i.e., the 10-seat version of this 

full-size van has eight tether anchorages 

available for use). The Alliance opined 

that there is no need to revise the zone 

such that these tether anchorages would 

no longer be permitted, given the easy 

access and visibility of tether 

anchorages. 

Similarly, Ford commented that the 

proposal to limit the tether anchorage 

location using a plane that is parallel to 

the torso line that passes through the 

‘‘rearmost point of the bottom of the 

seat’’ is overly restrictive for some freestanding seats (i.e., SUVs and vans). 

Ford suggested basing the forward-most 

limit of the acceptable zone on the 

SgRP. Ford proposed using a vertical 

plane 120 mm rearward of the SgRP as 

the forward limit of the acceptable zone, 

which would remove the ambiguity 

regarding the ‘‘rearmost point of the 

bottom of the seat’’ and, combined with 

labeling, permit some currently existing 

under-seat designs that do not have 

accessibility issues. Ford added that the 

plane is already specified in the 

standard to define the forward-most 

limit of the lower anchorage acceptable 

zone. Ford included three 

illustrations 80 depicting the current 

allowable under-seat zone, the 

allowable zone proposed in the NPRM, 

and a modified proposal that would 

limit the anchorage location to the plane 

120 mm rear of the SgRP. 

The Alliance and Honda requested 

clarification on how to define the 

intersection of the vehicle floor with a 

plane parallel to the torso line reference 

plane passing through the rear-most 

point of the bottom of the seat at the 

centerline of the seat. Both the 

Alliance 81 and Honda 82 presented 

illustrations of different scenarios where 

they indicated the rearmost point of the 

bottom seat was unclear and requested 

clarification. 

In addition, the Alliance explained 

that tether anchorages cannot be in the 

seatback if the seatback plane is located 

anterior 83 to the proposed line in figure 

3 of the proposed regulatory text in the 

NPRM. To prevent misinterpretation, 

the Alliance recommended removing 

the line from figure 3 in the proposed 

regulatory text in the NPRM or 

amending the requirement to call out 

this line as a line that represents the 

vehicle specific seatback surface within 

the prescribed zone, for the seatback 

profile similar to the callout for the 

vehicle floor pan. 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1305 

84Evaluation of FMVSS No. 225 Tether Anchor 

Zones Under the Seat. May 2022. Kedryn 

Wietholter, National Highway Traffic Safety 

Administration. Evaluation summary will be 

docketed along with this final rule. 85NHTSA chose to use the H-point as it can be 

measured in the laboratory as opposed to the SgRP, 

which is a manufacturer-defined point. Both points 

are very similar. 

Agency Response 

Comments expressing concerns over 

how the NPRM proposed to define the 

rearmost point of the bottom of the seat 

to locate the plane setting the limit of 

the allowable zone have merit. 

Therefore, following careful 

consideration and evaluation, this final 

rule adopts requirements to specify the 

allowable tether anchorage zone under 

the seat using a vertical plane 120 mm 

rear of the H-Point to define the 

allowable limit. 

Commenters presented several 

scenarios in which defining the 

rearmost point of the bottom of the seat 

was not possible, as the proposed 

requirement did not provide sufficient 

details on how to precisely define it. 

Commenters also stated that some 

existing easily accessible tether 

anchorages near the back of but slightly 

under the seat may not be compliant 

with the proposed tether anchorage 

zone. These anchorages are considered 

easily accessible because the seats do 

not require folding to access the 

anchorages and the anchorages can be 

easily identified since they have the 

proposed markings. 

In acknowledgment of these concerns 

the Agency did a series of installations 

and measurements to evaluate whether 

the vehicles with existing tether 

anchorages near the back but slightly 

under the seat are easy to use, and to 

determine whether the zone under the 

seat suggested by Ford is appropriate to 

define the allowable tether zone under 

the seat.84 NHTSA selected three 

vehicles (2015 Toyota Sienna, 2018 

Freightliner Sprinter, and 2020 Ford 

Transit) with tethers located low on the 

seatback (similar to the ones 

commenters stated were easily 

accessible locations) to evaluate 

whether they were easily accessed when 

installing a CRS, whether the tether 

anchorage location would fail to be 

located within the NPRM’s proposed 

allowable tether anchorage zone, and 

whether it would be within the Fordproposed allowable tether anchorage 

zone (defined by a vertical plane 120 

mm rearward of the SgRP as the forward 

limit of the allowable tether anchorage 

zone). 

In conducting the evaluation, NHTSA 

installed the Evenflo Triumph and the 

Britax Advocate Clicktight in the three 

selected vehicles to determine whether 

the tether was easily installed. The trials 

showed that the tether anchorages were 

easy to locate and use for attaching the 

CRS tether anchor connectors. 

NHTSA defined the allowable tether 

zones under the seat using both the 

NPRM’s proposed zone (parallel torso 

reference line that passed through the 

rearmost point of the bottom of the seat) 

and Ford’s proposed zone (defined with 

a vertical plane 120 mm rearward of the 

H-point) 85 in the three selected 

vehicles. These measurements were 

performed to verify whether Ford’s 

proposed method for defining the 

allowable tether zone under the seat 

would remove the ambiguities present 

in the NPRM’s proposed zone, and to 

evaluate whether the tether anchorages 

in the vehicles are located within the 

NPRM’s proposed allowable zone and/ 

or Ford’s proposed zone (but using the 

H-point rather than the SgRP suggested 

by Ford). 

The evaluations confirmed that 

defining the tether anchorage zone with 

the vertical line 120 mm behind the Hpoint removed the ambiguities 

contained in the NPRM’s proposed 

method. The evaluations showed that 

the tether anchorages of all three vehicle 

seats were easy to access and use for 

installing child restraints. However, 

these tether anchorages would not meet 

the allowable tether anchorage zone 

proposed in the NPRM, while they 

would pass using the 120 mm behind 

the H-point measurement method. This 

result indicates that an allowable tether 

anchorage zone determined as a plane 

120 mm rearward of the H-point better 

reflects ease of access and use of the 

tether anchorages than the NPRM’s 

proposed allowable zone. 

TABLE 1—SUMMARY OF TETHER ANCHORAGE LOCATION WITH RESPECT TO THE NPRM’S PROPOSED ALLOWABLE

TETHER ANCHORAGE ZONE AND THAT DETERMINED AS A PLANE 120 mm BEHIND THE H-POINT

Year Manufacturer Model Seat position Current zone NPRM zone Final rule zone 

(120 mm behind H-point) 

2015 .............. Toyota ........... Sienna ........... 2nd Row Driver Outboard.Pass .............. Fail ................ Pass. 

2018 .............. Freightliner .... Sprinter ......... 2nd Row Passenger Outboard.Pass .............. Fail ................ Pass. 

2020 .............. Ford .............. Transit ........... 2nd Row Passenger Outboard.Pass .............. Fail ................ Pass. 

The NPRM’s proposed requirement 

sought to eliminate tether anchorages 

located deep under the seat where 

folding the seat is necessary to reach it. 

NHTSA believes the limit on the tether 

anchorage location under the seat 

defined by a vertical plane 120 mm rear 

of the H-Point meets this intent. NHTSA 

also concludes that using a vertical 

plane 120 mm rearward of the H-point 

is easily defined, removes ambiguities 

commenters noted in the NPRM’s 

proposed tether anchorage zone, and 

better reflects the accessibility and 

usability of the tether anchorages. 

Therefore, the agency is adopting 

requirements to specify the allowable 

tether anchorage zone under the seat 

using a vertical plane 120 mm rear of 

the H-Point to define the allowable 

limit. This requirement will prevent 

tether anchorages from being located 

deep under the seat where they are 

difficult to access, addressing comments 

received. 

b. Tightening the Tether 

NHTSA proposed requirements to 

make it easier for a consumer to attach 

a child restraint tether hook to a tether 

anchorage and tighten the tether strap. 

Currently, FMVSS No. 225 specifies that 

tether anchorages must be located 

within the shaded zone shown in 

figures 3 to 7 of the standard for the DSP 


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1306 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

86The standard specifies a reference point ‘‘W’’ 

that is 50 mm (1.9 in) below and 50 mm (1.9 in) 

rearward of the shoulder reference point (R-point), 

and a reference point ‘‘V’’ that is 350 mm (13.7 in) 

vertically above and 175 mm (6.8 in) horizontally 

back from the H-point. The standard also specifies 

a strap wrap-around length of 200 mm (7.8 in) from 

the W-point and a strap wrap-around length of 250 

mm (9.8 in) from the V-point (see figure 4 of 

FMVSS No. 225). Tether anchorages may be located 

only within the zone that is generated using both 

reference points and their associated strap wraparound lengths to ensure there is sufficient distance 

for a tether strap and hook to be attached to the 

anchorage. 

87 Klinich, K.D., Flannagan, C.A., Manary, M.A., 

and Moore, J.L. ‘‘LATCH usability in vehicles.’’ 

Link: http://deepblue.lib.umich.edu/handle/ 

2027.42/90856. The report was sponsored by IIHS 

for developing IIHS’s rating of the usability of the 

child restraint anchorage systems in various 

vehicles. See IIHS Status Report: Vol. 47 No. 3, 

April 12, 2012. http://www.iihs.org/sr/default.aspx. 88This hardware consists of the tether hook and 

hardware to tighten and loosen the tether strap. 

89The rearmost point of the seat includes the 

head restraint if one is present. The V-point 

represents a low-mounted tether strap on a CRS and 

the W-point represents a high-mounted tether strap 

on a CRS. 

90The term wrap around distance is a distance 

measurement made using a flexible tape measure. 

One end of the tape is held at a defined point, the 

tape is wrapped around desired structures, and held 

taut at a second defined point. 

91The NPRM proposed to limit the tether hook 

and hardware to 165 mm (6.5 in). 

in which the anchorage is installed.86

NHTSA proposed to amend FMVSS No. 

225 to require that tether anchorages 

have clearance space for tightening the 

strap. 

The NPRM proposed to require a 165 

mm (6.5 in) minimum distance from 

each tether anchorage to a seat-based 

reference point for each designated 

seating position (DSP) with a tether 

anchorage. In 2012 the LATCH Usability 

study 87 found that, under the current 

FMVSS No. 225, tether anchorages can 

be located too close to the head 

restraint, on top of the seatback, or the 

tether attachment point on a CRS, 

resulting in insufficient clearance to 

tighten the CRS tether strap. The study 

reviewed the tether hardware assembly 

on 21 child restraint systems made by 

11 different CRS manufacturers.88 The 

review found the tether hardware 

assembly of the 21 child restraints 

ranged from 102 to 184 mm (4 to 7.2 in) 

in length, with 15 CRSs having tether 

hardware assembly lengths between 140 

mm (5.5 in) and 165 mm (6.5 in). The 

study suggested that having tether 

anchorages on a package shelf or behind 

the seatback at a distance of at least 165 

mm (6.5 in) rearward or below the back 

of the head restraint or top of the 

seatback for DSPs without a head 

restraint would provide greater 

clearance for attaching the tether hook 

of a CRS and tightening the strap. 

In drafting the NPRM NHTSA 

reviewed the LATCH usability study 

and tentatively determined that 

specifying a minimum 165 mm (6.5 in) 

distance from the tether anchorage to a 

defined reference point on the vehicle 

seat would improve tether anchorages’ 

ease-of-use. The NPRM explained that 

this clearance would allow for the 

tightening of tether straps in most 

vehicles without interference from other 

structures, such as the head restraint. 

The NPRM proposed that the 

reference point on the vehicle seat, 

which NHTSA designated as ‘‘SB,’’ be 

defined as the intersection of the plane 

parallel to the torso line reference plane 

(defined in figure 3 of FMVSS No. 225) 

that passes through the rearmost point 

of the seat and the wrap-around line 

from the ‘‘V-point’’ to the tether 

anchorage.89 The agency noted that both 

the V- and W-point could have been 

used for determining the vehicle seat 

reference point SB. NHTSA selected the 

V-point to define the reference point 

because it would encompass both low 

mounted and high-mounted tether 

straps. 

1. Tether Anchorage Location—165 mm 

to a Reference Point 

Comments on 165 mm Distance to 

Reference Point 

In response to the NPRM many 

vehicle manufacturers stated that 

requiring manufactures to move tether 

anchorages to locations meeting the 165 

mm (6.5 in) specification is impractical 

within current styling because 

substantial vehicle components 

currently occupy the locations. The 

Alliance stated that the relocation of a 

single component has implications for 

other design considerations including, 

but not limited to, wiring harnesses, 

body in white attachments and 

reinforcements, electromagnetic 

interference, and radio-frequency 

interference re-qualification. FCA stated 

that moving the tether anchorages 

rearward would force a complete 

redesign of the package shelf, including 

re-packaging of the existing package 

shelf components as well as moving the 

reinforcements. FCA said that if 

speakers or modules must be relocated 

to the door or the trunk changes to these 

components would also be necessary, 

including side impact countermeasures, 

door electrical wire harnesses, and 

interior trim modifications. The 

Alliance added that many passenger 

cars with tether anchorages located in 

the package shelf behind the seat will 

not meet the proposed 165 mm 

minimum wrap around distance,90 even 

though the anchorages are easy to use. 

Many vehicle manufacturers, the 

Alliance, and Global stated that tether 

anchorage distance and CRS hardware 

incompatibility should be addressed in 

FMVSS No. 213 by limiting the size of 

the tether hook and other CRS 

attachment hardware.91 Some vehicle 

manufacturers and the Alliance 

provided data on the sizes of tether 

hooks and hardware in stating that the 

lack of uniformity in CRS attachment 

hardware and its mounting location on 

the CRS point to the actual source of the 

compatibility issue, rather than the 

vehicle ‘‘swing zone’’ behind the 

seatback or head restraint. Hyundai 

stated that tight installations can be 

achieved even with vehicles that have 

less than the proposed 165 mm (6.5 

inches) distance, with a CRS tether 

hardware and strap measuring 170 mm 

(6.7 inches). 

The Alliance and Toyota identified 

potential problems with applying the 

proposed procedure to certain vehicles 

regarding the definition of the point SB. 

They presented a case for some head 

restraints where the torso reference 

plane may not intersect the strap wrap 

around line. Therefore, for this type of 

head restraint, the reference point SB 

does not exist. The Alliance and Toyota 

also presented a case in which the 

reference point SB cannot be defined 

when the seatback angle is larger than 

the torso angle. 

Toyota requested that NHTSA 

develop a repeatable and feasible 

requirement regarding the distance from 

the tether anchorage to the DSP. Toyota 

suggested that because the existence of 

reference point SB is dependent on the 

rearmost point of the seat, which can 

vary dramatically based on seat design, 

one potential method to solve this issue 

would be to develop a new tool to 

measure the distance of 165 mm from 

the tether anchorage instead of using the 

concept of reference point SB. 

Several commenters also suggested an 

alternative way of defining a clearance 

zone. FCA recommended a general 

redefinition of the reference point SB 

without providing a suggested 

definition. The Alliance opined that the 

proposed minimum wraparound 

distance, measured from point SB, is 

unnecessarily stringent and does not 

take current CRS installation practices 

into account. The Alliance and Honda 

recommended that a point farther 

forward in the vehicle DSP, representing 

a tether attachment point on a child 

restraint, would provide a more 

practicable reference point for this 

measurement. 

Britax stated that mandating a 

minimal vehicle interior distance 

should facilitate better tether 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1307 

92 Klinich, K.D., Boyle, K., Orton, N.R., Manary, 

M.A., & Ebert, S. (2016, January). Investigation of 

clearance criterion between tether anchor and head 

restraint. Ann Arbor: University of Michigan 

Transportation Research Institute. Report will be 

docketed alongside this final rule. 

93ADR 34 Link: https://ablis.business.gov.au/ 

service/vic/australian-design-rule-adr-34-childrestraint-anchorages-and-child-restraint-anchorfittings/24383. This standard specifies a clearance 

around the tether anchorage to enable access and 

attachment of the tether hook to the anchorage. 

94See Table 1 in the report titled ‘‘Investigation 

of clearance criterion between tether anchor and 

head restraint’’ by UMTRI. Report will be docketed 

along this final rule. 

95The other 10 vehicles were sedans. 

96 IIHS LATCH usability rating considers tether 

anchorages located in the top 85 percent of the seat 

back as ‘‘good.’’ The IIHS LATCH Usability Rating 

Guidelines can be found here: www.iihs.org/media/ 

8f828313-d122-4d27-a3b0-f2b8ec60065d/wOdYVA/ 

Ratings/Protocols/current/LATCH_rating_

guidelines.pdf (last accessed 4–16–2024). 

97The Ford F150 was not evaluated, as pickup 

trucks have different geometry. 

98See Table 1 in UMTRI’s report for detailed 

results. Klinich, K.D., Boyle, K., Orton, N.R., 

Manary, M.A., & Ebert, S. (2016, January). 

Investigation of clearance criterion between tether 

anchor and head restraint (Report No. UMTRI– 

2016–4). Ann Arbor: University of Michigan 

Transportation Research Institute. Report will be 

docketed along with this final rule. 

99See Table 2 in UMTRI’s report for detailed 

results. Klinich, K.D., Boyle, K., Orton, N.R., 

Manary, M.A., & Ebert, S. (2016, January). 

Investigation of clearance criterion between tether 

anchor and head restraint (Report No. UMTRI– 

2016–4). Ann Arbor: University of Michigan 

Transportation Research Institute. Report will be 

docketed along with this final rule. 

installation, particularly in sedan 

vehicles with rear windows close to rear 

seatbacks. Britax anecdotally noted it 

has experienced situations where the 

distance between the vehicle seat and 

tether anchorage would not permit 

proper tether attachment and tightening. 

UMTRI supported the implementation 

of a 165-mm clearance around the tether 

anchorage in vehicles and the regulation 

of a maximum adjusted length of the 

tether attachment hardware to 165 mm 

to improve compatibility. UMTRI noted 

that these recommendations were based 

on usability testing of CRS with a single 

strap tether. 

Post NPRM Research 

UMTRI Research 

After carefully reviewing comments 

that raised concerns over the proposed 

165 mm tether anchorage clearance 

criterion, the agency determined that it 

was appropriate to task UMTRI with 

conducting a study 92 to: (1) define an 

alternate reference point to the proposed 

SB point that would be more practical, 

(2) ensure that the requirements do not 

interfere with Australian Design Rule 

(ADR) 34/2,93 (3) estimate the number of 

vehicles that may need modification to 

meet clearance criteria based on the 

proposed and alternative reference 

points, and (4) evaluate alternative ways 

of ensuring tether tightness. 

In carrying out its study UMTRI used 

two data sets to estimate the proportion 

of vehicles that would meet the 

proposed 165-mm clearance criteria. 

First, UMTRI surveyed 60 top selling 

2012–2013 MY vehicles to collect data 

on each vehicle’s tether anchorage 

location, head restraint characteristics, 

and tether routing path. UMTRI used a 

rigid 165-mm gauge with tether hook to 

evaluate whether the tether anchorage 

location met the proposed criteria. This 

data set showed that 21 of the surveyed 

vehicles had tether anchorages on the 

rear package shelf. Eighteen of these 

vehicles were sedans and three were 

pickup trucks. Of the sedans, only one 

met the proposed criteria. For the 17 

sedans that did not meet the NPRM’s 

proposed criteria, routing the tether over 

the head restraint improved access to 

the tether hardware. 

UMTRI surveyed photos of the 21 

vehicles with a tether in a package shelf 

to evaluate potential barriers in moving 

the tether anchorages. About half of the 

vehicles had no visible barriers at 

outboard seating positions, two vehicles 

had potential for interference from rear 

window glazing during installation, and 

the remaining vehicles had speakers in 

the way. The center seating position in 

5 vehicles had rear defroster structures 

that may be in the way of relocation. 

The second data set used a survey of 

98 top selling 2010–2011 MY vehicles. 

The tether anchorage location was 

measured for these vehicles via 

wraparound distance relative to an 

estimated shoulder reference point. 

These surveys collected photos that 

helped identify structures that would 

hinder any tether anchorage relocation 

if the 165 mm criterion was not met. 

Data from the 98 vehicle-dataset showed 

that 44 percent of vehicles with the 

tether anchorage on the seatback would 

meet the 165 mm criterion. Of the 35 

vehicles with the tether anchorages 

located in the package shelf of the 

outboard seating position, 24 percent 

would not meet the 165 mm criterion, 

but could improve usability if the tether 

was routed over the head restraint. 

UMTRI then developed an alternate 

reference zone using established 

reference points such as the H-point 

(hip point) and the R-point (shoulder 

point) using 21 vehicles (MY2010–2014) 

scanned by UMTRI during previous 

projects.94 A circle with a 325 

millimeter radius centered on the Rpoint and truncated 230 mm below its 

center was used to create the limits of 

the allowed tether anchorage zone. 

UMTRI evaluated 11 SUVs and trucks 

in the scanned vehicle dataset 95 that 

had an upper seatback tether anchorage 

location. To avoid conflicts with the 

IIHS usability rating criteria 96 the circle 

was truncated at 230 mm below the Rpoint. Doing so allowed for the tether 

anchorage to be located far enough to 

ensure tightness while not conflicting 

with IIHS usability rating criteria. 

UMTRI evaluated the proposed and 

alternative tether anchorage clearance 

criteria against 20 of the 21 97 scanned 

vehicles (MY2010–2014) to determine 

whether vehicles met the proposed 

distance criteria and quantify the 

distance a tether anchorage would have 

to be relocated if that vehicle did not 

meet the proposed or alternative 

criteria. Results were mixed.98 Eleven 

models met both criteria. Four failed 

both criteria but using the alternative 

criterion the tether anchorage relocation 

distance was shorter than for the 165 

mm clearance criterion. Two passed the 

alternative criterion but failed the 165 

mm criterion. Two vehicles with tether 

anchorages in the upper seatback (and 

not the package shelf) passed the 165 

mm criterion but failed the alternative 

criterion. For these two vehicles, 

tightening the tether was difficult for 

installing some child restraints. The 

tether anchorages for these two vehicles 

would need to be moved 1–2 mm lower 

to meet the 325 mm truncated sphere 

zone, which would also permit 

tightening the tether. 

UMTRI also performed in-vehicle 

evaluations for both tether anchorage 

clearance criteria on 10 vehicles (MY 

2004–2014).99 For this set of vehicles 

UMTRI found that three vehicles failed 

both criteria, while seven met both 

criteria. Of the three vehicles that failed 

both criteria, the distance to move the 

tether anchorages to meet the alternative 

criterion was shorter than that for 

meeting the proposed criterion in two 

vehicles. 

In its review of the two vehicle 

surveys UMTRI found that about onethird of vehicles had tether anchorages 

located on the package shelf and that 

the majority did not meet the 165-mm 

criteria if the tether strap was specified 

for routing under the head restraint. 

However, UMTRI found that in most of 

these vehicles routing the tether strap 

over the head restraint provided good 

access to the tether adjuster hardware. 

VRTC Research 

Following review of the UMTRI 

study, VRTC evaluated the alternative 

criterion (zone based on a 325 mm circle 

centered on the R-point), the proposed 

165 mm clearance distance, and the 


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1308 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

100Wietholter, K., & Smith, J. (2019, November). 

Evaluation of tether anchor zones for FMVSS No. 

225 (Report No. DOT HS 812 842). Washington, DC: 

National Highway Traffic Safety Administration. 

Report will be docketed along with this final rule. 

101A FARO arm is a portable coordinate 

measuring machine that measures the location of a 

probe in a 3D space. 

lengths of CRS tether hardware.100

VRTC measured six vehicles with 

various tether anchorage locations in the 

rear driver side position and rear center 

position. 

Tether Anchorage Measurements 

The VRTC Tether Anchorage 

Measurement results were similar to 

those found by UMTRI (see Table 2). 

The six vehicles’ seating positions with 

package shelf tether anchorages failed 

the proposed 165 mm distance. Only 

two of those six tether anchorages failed 

the alternative criterion. Of the two 

vehicles that failed both criteria, the 

needed relocation distance of the tether 

anchorage to meet the criteria was 

smaller for the alternative criterion than 

the proposed criterion. All seating 

positions with the tether anchorage on 

the seatback or roof passed both criteria. 

TABLE 2—VRTC TETHER ANCHORAGE VEHICLE SURVEY RESULTS

Vehicle Tether location 

325 mm zone 

(mm) 

165 mm tether 

distance 

Year Make Model (mm) 

Rear driver 

position 

(RDP) 

Rear center 

position 

(RCP) 

2010 Ford Taurus .......................................................................... Package Shelf ....... ................................ 384 149 

Package Shelf ....... 436 141 

2011 Cadillac CTS ......................................................................... Package Shelf ....... ................................ 294 68 

Package Shelf ....... 409 74 

2016 Toyota Sienna ....................................................................... Seatback ............... ................................ 742 757 

N/A ........................ N/A N/A 

2011 Hyundai Sonata .................................................................... Package Shelf ....... ................................ 308 75 

Package Shelf ....... 365 65 

2016 Chevrolet Tahoe ................................................................... Seatback ............... ................................ 625 657 

Seat Back .............. 628 637 

2016 Nissan Rogue ....................................................................... Seatback ............... ................................ 433 469 

Roof ....................... 630 460 

VRTC found one of the six vehicles’ 

tether anchorages was off-center for its 

designated seating position. VRTC used 

a FARO arm 101 to plot the desired 

points into a 2D circle diagram. Due to 

the offset, measurements for that tether 

anchorage do not correctly capture the 

depth distance. Therefore, VRTC used a 

325 mm sphere (truncated at the 

bottom) instead of a two-dimensional 

circle to define the 325 mm zone (see 

figure 4). 

CRS Hardware Measurements 

VRTC also measured the tether 

hardware length of twenty CRSs. The 

longest tether strap hardware was 190 

mm. The shortest was 83 mm. Sixteen 

of the twenty tether hardware were less 

than 165 mm in length. 

CRS Installation on Vehicles 

VRTC completed CRS installations to 

verify that a vehicle with a 165-mm 

tether anchorage distance measurement 

would allow for proper installation of a 

CRS with a tether hardware length of 

165 mm. The CRS selected was an 

Evenflo Triumph with a tether hardware 

length of 164 mm. Two vehicles with 

short distances (close to the 165 mm 

proposed minimum distance) to the 

tether anchorage were selected for this 

portion of the study. The 2010 Ford 

Taurus (RDP), which had a 149-mm 


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Figure 4. Three-Dimensional 325 mm Zone. 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1309 

102Australian Design Rule 34. The stated function 

of this Australian Design Rule is to specify 

requirements for ‘‘Child Restraint Anchorages’ and 

‘Child Restraint Anchor Fittings’ which provide for 

the connection of standard ‘Attaching Clips’ so that 

‘Child Restraints’ may be adequately secured to the 

vehicle. It specifies a standard package of fitting 

hardware and accessibility requirements to 

facilitate correct installation and interchangeability 

of ’Child Restraints’. www.infrastructure.gov.au/ 

infrastructure-transport-vehicles/vehicles/vehicledesign-regulation/australian-design-rules/thirdedition. Last accessed November 4, 2024. 

tether anchorage distance measurement, 

was closer to 165 mm than the other 

selected vehicle. The 2011 Cadillac CTS 

(RCP) had one of the smaller tether 

anchorage distance measurements of 74 

mm and an odd seat shape. Both the 

2010 Ford Taurus (RDP) and 2011 

Cadillac CTS (RCP) positions passed the 

UMTRI alternative criterion based on 

the 325-millimeter circle centered on 

the R-point. 

Because the 2010 Ford Taurus (RDP) 

had a tether anchorage distance 

measurement from the proposed SB 

point of less than 165 mm, the study 

anticipated that the tightening of the 

tether would be difficult. However, the 

vehicle owner’s manual included 

instructions to install the CRS using the 

tether attachment by routing it under 

the head restraint. Since the head 

restraint was adjustable, no difficulties 

were experienced when tightening the 

tether. This result suggests that the 

tether anchorage distance measurement, 

defined as the distance from the tether 

anchorage to the rearmost point on the 

seat (SB point), does not account for the 

ease of installation when the head 

restraint is raised or removed for CRS 

installation. 

Further, since the tether anchorage 

distance from the SB point for the 2011 

Cadillac CTS (RCP) was only 74 mm 

(significantly lower than the proposed 

165 mm), NHTSA expected that the 

tether would be difficult to tighten 

when installing a CRS in this seating 

position. However, installation was not 

difficult because of the lack of head 

restraint. Specifically, the seatback 

cushion in the Cadillac was thick, 

which allowed enough space between 

the tether anchorage and the CRS for the 

tightening of the hardware. For the 2011 

Cadillac CTS (RDP), the vehicle owner’s 

manual specified that the CRS tether 

attachment should be routed over the 

fixed head restraint, which permitted 

easy tightening of the tether attachment. 

If a vehicle with similar spacing had an 

adjustable head restraint and specified 

routing under the head restraint in the 

vehicle owner’s manual, it would have 

been difficult to tighten the tether 

attachment because the tether 

attachment hardware would be 

underneath the head restraint. This 

finding indicates that ease of 

installation can be improved with 

vehicle owner’s manual instructions 

and not just measurement requirements. 

Agency Response 

After carefully considering comments 

received and reviewing the results of the 

UMTRI and VRTC studies, this final 

rule is implementing a 325 mm radius 

sphere zone (from R point, with 

truncation) instead of the NPRM’s 

proposed 165-mm distance from the 

tether anchorage to the back of the 

seatback. The decision to adopt the 

alternative 325 mm zone resolves noted 

issues in defining the SB point for the 

165-mm distance, because the R-point, 

already defined in the standard, is used 

in the alternative 325 mm radius sphere 

zone to define the center of the sphere. 

Therefore, NHTSA will adopt a 325 mm 

radius sphere zone (from R-point, with 

truncation) to define the allowable area 

for the tether anchorages. 

Some commenters, including Honda, 

Alliance, Ford, and FCA, expressed 

concern for the expensive tooling costs 

needed to relocate the tether 

anchorages. However, the modified 

requirements adopted by this final rule 

will minimize or eliminate the number 

of vehicles that need tooling changes to 

relocate the tether anchorages, greatly 

reducing any projected tooling costs. 

NHTSA acknowledges Honda’s 

suggestion that the required minimum 

distance of the tether anchorage should 

be from a point simulating the 

attachment of the tether strap on the 

CRS to the tether anchorage, rather than 

the SB point. However, the current 

specifications of the tether anchorage 

location in FMVSS No. 225 are with 

respect to the W-point, which is 

approximately the tether strap 

attachment point on the CRS. 

Additionally, this final rule’s 

requirements specify a minimum 

distance of the tether anchorage with 

respect to the R-point, which was found 

to be sufficient for correctly installing 

and tightening the tether of CRSs. This 

final rule’s adopted approach achieves 

the goal of improving usability in a 

practicable manner without imposing 

design restrictions and undue cost and 

redesign. 

Finally, NHTSA is providing a longer 

lead time (discussed in detail below) to 

minimize any costly design changes 

borne by manufacturers to move tether 

anchorage locations during the midlifecycle of their vehicles. 

Comments on Backlight Interference 

Several commenters, including FCA, 

the Alliance, and Hyundai, raised 

concerns that moving the tether 

anchorage rearward will likely interfere 

with the backlight during child restraint 

tether hook attachment and detachment. 

FCA noted that the slope of the back 

glass may need to be changed to 

alleviate the interference condition. 

FCA further stated that all of its current 

tether anchorages are harmonized 

worldwide and that, if NHTSA 

mandates relocating the tether 

anchorage rearward, its vehicles may no 

longer meet the requirements of 

ADR34,102 which governs child restraint 

anchorages for vehicles sold in 

Australia. FCA stated that ADR 34.6 

requires accessibility to engage an 

attaching clip and a clearance zone 

around the tether anchorage. FCA stated 

that, in the worst-case event, two 

designs for the package shelf might be 

necessary, which would increase the 

overall vehicle cost in all markets. The 

Alliance stated that the proposed 

requirement’s forced relocation of tether 

anchorages rearward in the vehicle 

would result in less hand clearance to 

the vehicle backlight for attaching and 

detaching the tether hook. 

Agency Response 

With this final rule’s adoption of the 

aforementioned changes in determining 

the allowable tether anchorage zone, 

any cases where the tether anchorage is 

pushed back towards the rear window, 

causing potential conflict with the ADR, 

will be minimized or eliminated. 

However, UMTRI’s evaluations of the 

updated measurement showed a small 

portion of vehicles would still 

experience conflict based on the 

requirements of this final rule, so some 

vehicle designs would have to find 

alternative locations or design to meet 

both ADR 34 requirements and FMVSS 

No. 225 requirements. To the extent 

doing so is required, the extended lead 

time and phase-in period provided by 

this final rule should help to alleviate 

cost and design burdens to 

manufacturers. 

Comments on Head Restraints and 

Routing of Tether 

The Alliance suggested that the tether 

anchorage location requirements 

relative to the back of the seat or head 

restraint should not apply to vehicle 

seating positions (1) without a head 

restraint, (2) with a head restraint that 

is removed for child restraint 

installation, or (3) when the vehicle 

manufacturer specifies that the tether 

strap is to be routed over or around the 

head restraint. Similarly, Global 

commented that the tether anchorage 

location requirements should not apply 

to seats having adjustable or removable 


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103Shown in figure 16 of the Alliance’s submitted 

comments. Link: www.regulations.gov/comment/ 

NHTSA–2014–0123–0027. 

head restraints, since such head 

restraints can be adjusted or removed to 

allow sufficient space for tether 

adjustment. Global agreed that the 

distance criterion might be applied to 

certain seats having a fixed head 

restraint, where there is no space 

between the head restraint and the seat 

top to enable tightening of the tether 

strap. 

Agency Response 

Following careful consideration, this 

final rule requires vehicles with 

adjustable/removable head restraints 

and no head restraints to locate the 

tether anchorages beyond the 325 mm 

truncated sphere from the R point to 

ensure tethers can be easily tightened. 

The agency disagrees with the 

Alliance’s recommendation that the 

tether anchorage location requirement 

behind the seat should not apply to 

DSPs with no head restraints and 

removable head restraints. Vehicles in 

this category could run the risk of 

having the tether anchorage too close to 

the CRS, preventing a tight tether 

installation. While the tether could be 

routed over the adjustable/removable 

head restraint, thereby increasing the 

wraparound distance to the tether 

anchorage and removing interferences 

for tightening the tether strap, most 

manufacturer instructions specify 

routing the tether strap under the 

adjustable/removable head restraint. 

Routing the tether under the head 

restraint provides the shortest path from 

the tether anchorage to the CRS, which 

may have some benefits during a crash 

(less webbing length results in less 

stretch). Routing the tether under the 

head restraint may also offer improved 

CRS performance in far side impact 

scenarios as tether routings over the 

head restraint sometimes slip to the side 

of the head restraint, allowing for more 

side excursion. In addition, because 

some head restraints that protrude or tilt 

to the front at times interfere with the 

installation of the CRS, it is typically 

advised to remove or move the head 

restraint to a higher position to 

eliminate this interference. Because 

adjustable/removable head restraints are 

likely to be used with a tether routed 

under the head restraint (for adjustable 

head restraints), it is important to have 

the tether anchorage beyond the 325 

mm truncated sphere from the R point 

to ensure tethers can be easily tightened. 

In contrast with the Alliance’s 

recommendation, Global suggested that 

the requirement for the tether anchorage 

location behind the seat should only 

apply to DSPs with fixed head 

restraints. We disagree. As fixed head 

restraint seating positions do not have 

any elements that interfere with the 

installation and tightening of the tether, 

the agency believes these seating 

positions should be excluded from the 

tether anchorage location requirements 

to ensure there is sufficient space to 

tighten the tether. Additionally, seating 

positions with fixed head restraints 

where the tethers are routed over the 

restraints increase the wraparound 

distance from the CRS to the tether 

anchorages, so they are less likely to 

prevent tightening of the tether due to 

limited distance. Finally, there is no 

interference of the head restraint to 

route and tighten the tether for seats 

with fixed head restraints. For these 

reasons, this final rule excludes DSPs 

with fixed head restraints from the 

tether anchorage location requirements. 

Comments on Tether Anchorage 

Location and Pass-Through Door 

The Alliance expressed concerns with 

relocating the center tether anchorage as 

proposed in the NPRM in relation to a 

specific design featuring a tether 

anchorage installed above a luggage 

compartment pass-through door.103 The 

Alliance stated that the proposed 

minimum wraparound distance would 

necessitate a tether anchorage position 

lower on the seatback. The Alliance 

explained that to accommodate this 

revised tether anchor position, the size 

of the pass-through door/opening to the 

luggage compartment would need to be 

smaller, thereby significantly limiting 

its usefulness. The Alliance stated it is 

not practicable to locate the tether 

anchorage on the pass-through door 

because the door lacks the structural 

strength to meet FMVSS No. 225’s tether 

anchorage strength requirements. The 

Alliance recommended that the center 

seating position should thus be 

exempted from the minimum tether 

anchorage distance requirement relative 

to the SB point. 

Agency Response 

The modified requirements adopted 

by this final rule will minimize or 

eliminate the tooling costs that would 

be necessary to relocate the tether 

anchorages, and will minimize or 

eliminate cases where the tether 

anchorage location could interfere with 

the position of a pass-through on a 

center seat (if the tether anchorage 

cannot be located elsewhere). If a tether 

anchorage can’t be located towards the 

top of the seat within the new 

requirements because of a pass-through 

opening, the tether anchorage could 

instead be located lower in the seat 

where a tether strap would go over the 

pass-through opening area. This 

scenario would not interfere with the 

function of the pass-through door 

because it would not be used when a 

CRS is installed in the center seating 

position. As such, the agency is 

declining to adopt the proposed 

exemption. 

Comments on the Need for Vehicle 

Manual Information 

SRN stated that head restraints 

present a significant impediment to 

tethering the CRS in many vehicles and 

recommended that FMVSS No. 225 

require vehicle manuals to provide 

specific instruction for the proper 

routing of the tether vis a vis the head 

restraint, along with clear guidance for 

how to adjust the head restraint to 

achieve proper routing when necessary. 

SRN explained that because tethers 

come in two styles that affect routing 

(two-point and three-point), instructions 

should be required to address these 

differences. SRN also stated that 

instructions calling for the removal of 

the head restraint should clarify 

whether the head restraint can be 

reattached once the tether is attached, 

or, if not, where the head restraint 

should be safely stored. SRN stated that 

some vehicle owner’s manuals have 

improved these types of instructions 

over the years, but that this 

improvement is far from consistent. 

SRN also stated that in some cases, 

cargo covers, dog gates, and other 

accessories supplied by the vehicle 

manufacturer impede the route of a 

tether to the tether anchorage. Based on 

these issues, SRN suggested that the 

manufacturer be required to provide 

clear tether routing instructions in the 

vehicle’s manual. 

Agency Response 

The agency is declining SRN’s 

suggestion to require tether routing 

instructions in vehicle manuals, as it 

falls outside scope of the proposed 

requirements in the NPRM and this 

rulemaking. NHTSA may consider the 

addition of instructions for tether 

routing in vehicle owners’ manuals at a 

later date. 

Comments on the Length of the 

Minimum Distance to the Tether 

Anchorage and Maximum Length of the 

Tether Hardware 

SRN supported efforts to match up the 

distance from the child restraint to the 

tether anchorage and a maximum length 

of the tether hardware (the hook + 

adjuster). However, SRN expressed 

concern that by specifying 6.5 inches as 


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both the minimum for the distance from 

the child restraint to the vehicle’s tether 

anchorage and a maximum for the very 

shortest tether length, it will continue to 

be difficult to properly tighten the tether 

when both the CRS and vehicle meet 

(but do not exceed) the standard. SRN 

stated that the minimum distance to the 

tether anchorage should be at least a 

half inch (or more) greater than the 

maximum-allowed fixed length of the 

tether anchorage for the solution to be 

effective in all situations (for example, 

the shortest length for the tether hook 

and adjuster could be a maximum of 6 

inches and the tether anchorage 

distance no less than 6.5 inches). 

Agency Response 

SRN commented that having the same 

165 mm distance as the requirement to 

both the tether anchorage distance and 

the tether hardware length does not 

ensure proper tightening of the tether, 

commenting that the minimum distance 

of the tether anchorage needs to be at 

least a half inch (or more) greater than 

the maximum allowed fixed length of 

the tether hardware for the solution to 

be effective. As the final rule 

requirements for tether anchorage 

location have been modified from those 

proposed in the NPRM, SRN’s 

suggestion no longer applies to this final 

rule. 

In support of the modifications 

adopted in this final rule, during the 

VRTC CRS hardware survey, only 4 of 

the 20 CRSs had hardware exceeding 

the 165 mm limit. This finding supports 

NHTSA’s decision to adopt a tether 

hardware length requirement of 165 mm 

or less as proposed, as most CRSs 

already comply with this length. Any 

changes needed to the tether hardware 

design in CRSs that currently do not 

meet this length should not be 

burdensome, as there are many tether 

hardware designs available that meet 

the requirement. Further, this 

requirement will help address the 

Alliance and FCA’s suggestions to 

promote CRS uniformity. 

Comments on Requiring Tether 

Anchorages To Be Close to the Proposed 

165 mm Requirement 

ARCCA commented that NHTSA’s 

assessment of tether anchorage locations 

appeared to only consider the tether’s 

effectiveness in frontal crashes. ARCCA 

stated that side impact crashes can 

result in a similar number of injuries 

and fatalities as frontal crashes, and that 

they should be given equal 

consideration. ARCCA explained that 

the tether is most effective in frontal 

crashes, and that a tether also reduces 

the amount of roll that a forward-facing 

CRS experiences when the tether length 

is sufficiently limited. ARCCA added 

that its own sled testing and quasi-static 

load testing indicate that the longer the 

tether, the more the CRS can roll 

towards the impact during a side 

impact, and that an increased CRS roll 

results in increased lateral head 

excursion. ARCCA explained that this 

increased head excursion results in 

increased head impact injuries, the most 

frequent mechanism of serious injury. 

For these reasons, ARCCA 

recommended that tether anchorage 

locations should be limited to the 

package shelf and the back of the 

vehicle seat, and as close to the 

proposed 165 mm (6.5-inch) minimum 

as possible. Alternatively, ARCCA 

recommended that when the distance of 

the tether anchorage exceeds the 165 

mm (6.5-inch) minimum, a tether guide 

should be provided at the back top of 

the seatback that has sufficient strength 

to maintain the tether within the guide 

during side impact crashes. 

Agency Response 

This final rule will not reduce the 

allowable tether anchorage zone to 

distances close to 165 mm from the SB 

point as possible, as suggested by 

ARCCA, because doing so would greatly 

reduce the allowable tether zone in the 

standard and may not be feasible in 

some vehicle designs. 

ARCCA’s suggested proposal to 

include a tether guide is not within the 

scope of this rulemaking, and will thus 

not be addressed, as it was not proposed 

in the NPRM and NHTSA does not have 

any data on tether guides to aid in side 

impact crashes. 

Requests for Clarification 

Global requested clarification of the 

following: 

• Which portion of the routing device 

will be the reference position for the 

165-mm distance measurement? 

• How much force is to be applied on 

the strap when making the 

measurement? 

Agency Response 

As the agency is not adopting the 165 

mm distance from the SB point to the 

tether anchor, these requested 

clarifications are moot and need not be 

addressed, as they do not relate to 

requirements of this final rule. 

2. Tether Hardware Restrictions 

To improve compatibility between 

vehicles and CRSs, NHTSA proposed to 

amend FMVSS No. 213 to require that 

the tether hardware assembly 

(consisting of the tether hook and 

hardware to tighten and loosen the 

tether strap) be no longer than 165 mm 

(6.5 in). NHTSA proposed this limit so 

that all CRS tether straps can be 

tightened given the minimum tether 

anchorage distance from the SB 

reference point. NHTSA stated that 

limiting the length of the tether 

hardware assembly would not be overly 

burdensome for CRS manufacturers, 

since the assembly consists of simple 

parts. 

General Comments 

The Alliance and FCA opined that the 

tether anchorage distance and CRS 

hardware incompatibility is better 

addressed through the introduction of 

design rules for the attachment 

hardware in FMVSS No. 213. The 

Alliance stated that a survey of 16 child 

restraints manufactured between 2003 

and 2014 found that attachment 

hardware lengths varied from 120.6 to 

171.4 mm (4.75 to 6.75 inches) in 

length, tether hooks alone varied from 

60.3 to 63.5 mm (2.375 to 2.5 inches) in 

length, and adjuster assemblies varied 

in both length and circumference (from 

120.6 to 196.8 mm (4.75 to 7.75 inches) 

in circumference). The Alliance stated 

that the lack of uniformity in CRS 

attachment hardware and its mounting 

location on the CRS points to the actual 

source of the compatibility issue, rather 

than the vehicle ‘‘swing zone’’ behind 

the seatback or head restraint. Similarly, 

Hyundai presented a 12 CRS hardware 

length survey that found a range 

between 140 to 185 mm (5.5 to 7.3 

inches). Hyundai stated that limiting the 

length of the tether hardware assembly 

would not be overly burdensome for 

CRS manufacturers, since that assembly 

consists of simple parts. 

Britax recommended against adopting 

restrictive dimensional requirements for 

tether hardware length (165 mm), as it 

might prevent advancement in tether 

technologies, and against requiring 

child restraint manufacturers to modify 

current tether hardware design. Instead, 

Britax recommended that child restraint 

manufacturers simply provide 

compatible tether hardware as the 

vehicle tether anchorage dimensions are 

standardized. 

Agency Decision 

This final rule adopts a tether 

hardware length requirement of 165 mm 

or less as proposed by the NPRM. Most 

CRSs already comply with this length 

and changing the tether hardware 

design in CRSs that currently do not 

meet this requirement should not be 

burdensome, as there are many tether 

hardware designs available that can 

meet the requirement. Although Britax 

did not describe how a new tether 


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104See details of attachment to the tether 

anchorage at https://us.britax.com/why-britax/ 

innovation/v-shaped-tether. 

105 Jessica B. Cicchino, J.B., Jermakian, J.S. 

‘‘Vehicle Characteristics Associated with LATCH 

Use and Correct Use in Real-World Child Restraint 

Installations.’’ April 2014. 

106 Illustration can be found on page 14 of 

Alliance comment submission in Docket No. 

NHTSA2014–0123–0027. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0027. 

107 Illustration can be found on page 13 of 

Alliance comment submission in Docket No. 

NHTSA2014–0123–0027. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0027. 

108Marking requirements are discussed in a later 

section of this final rule. 

technology would not be able to comply 

with this requirement, any hardware 

design with a longer distance than 165 

mm could prevent tight installations, 

and therefore, would not comply. 

Having this requirement will also 

address the Alliance and FCA’s 

suggestion to promote CRS uniformity. 

V-Shaped Tethers 

Britax stated it has a patented tether 

technology which incorporates, in part, 

a V-shaped tether assembly. Britax 

stated that the V-shaped tether assembly 

would meet the proposed tether 

hardware length requirement. In 

contrast, UMTRI stated that for Vshaped tethers, the adjustment hardware 

is typically located a considerable 

distance from the tether hook, so these 

tethers may not be able to comply with 

the proposed requirement. UMTRI also 

stated that has had had difficulties 

tightening the V-shaped tether in some 

Britax CRSs. 

Agency Decision 

Unlike common tethers that are 

usually routed directly from the middle 

of the CRS back to the tether anchorage, 

a V-shaped tether is routed from the two 

CRS attachments near the side of the 

CRS back to the tether anchorage.104 A 

V-shaped tether would most likely have 

a longer distance from each of the back/ 

side attachment points to the tether 

anchorage and would not have a head 

restraint interfering during attachment, 

as it is routed on either side of the head 

restraint. Factors outside the scope of 

the proposed requirements on tether 

anchorage location and tether hardware 

length may be the cause of difficulties 

in tightening V-shaped tether 

anchorages. However, any potential 

solution is out of scope of this 

rulemaking and will thus not be 

addressed by this final rule. 

c. Noticing the Tether Anchorages 

1. Structures Covering Anchorages 

The NPRM proposed to require that a 

tether anchorage must be in a location 

where the anchorage is accessible 

without the need to remove carpet or 

other vehicle components to access the 

anchorages. However, the NPRM 

proposed that a tether anchorage may be 

covered with a cap, flap, or cover, 

provided that the cap, flap, or cover is 

specifically designed to be opened, 

moved aside, or otherwise provide 

access to the anchorage. It must also be 

labeled with the ISO symbol indicating 

the presence of the tether anchorage 

underneath. The NPRM also proposed 

to require the anchorage to be accessible 

without the use of any tools, including 

the use of a screwdriver or coin. 

Covered Tether Anchorages 

Dr. Baer strongly disagreed with the 

provision allowing for the covering of 

tether anchorages with any cap/flap/ 

cover, stating concerns that parents do 

not notice these covers, because vehicle 

manufacturers do a very good job of 

making the caps/flaps/covers blend in 

with their surroundings. Dr. Baer stated 

that aesthetics of the vehicle need to 

take a back seat to child safety, and that 

hiding of the CRAS has directly 

contributed to the failure of CRAS to 

reduce misuse rates in the population as 

a whole since so many parents never 

find the anchorages in their vehicles. 

Agency Response 

The agency disagrees that tether 

anchorage covers should not be allowed. 

Data from IIHS’s study 105 shows that 

the package shelf is the tether anchorage 

location most widely used in the field. 

Tether anchorage covers are most 

commonly used in package shelf 

locations and are usually voluntarily 

labeled with the ISO tether symbol. 

Although IIHS data does not provide 

details on whether the tether anchorages 

in their study had covers or not, data in 

the IIHS study suggests that it is not 

detrimental to have a labeled cover on 

the tether anchorages. 

Cargo Covers 

The Alliance stated that many SUVs, 

CUVs, and station wagon-type vehicles 

are equipped with a luggage 

compartment cover. The Alliance stated 

that some of these cover designs must be 

removed when access to the tether 

anchorages is required, while others are 

retracted into their own housing.106 The 

Alliance commented that the 

compartment cover removal does not 

require any special tools and is, in most 

cases, conducted with a simple twist, 

turn, and lift-up movement of the 

hardware. The Alliance added that in 

some hatch-back and coupe style 

vehicles, the package shelf may have to 

be moved/removed temporarily to 

facilitate accessing the tether anchorages 

on the vehicle seatback.107

The Alliance provided examples of a 

hatchback equipped with a lightweight 

removable security cover hinged near 

the seatback on one side and tethered to 

the rear hatch on the other side. The 

Alliance explained that the cover is 

designed to be easily removed to 

transport large cargo when the rear seat 

is folded flat and that the cover needs 

to be temporarily lifted or removed to 

attach the tether to the tether anchorage 

located on the vehicle structure. The 

Alliance added that removing the cover 

is not an impediment to tethering the 

CRS and the regulation should not 

prohibit manufacturers from providing 

the security the covers provide. The 

Alliance stated that because these 

compartment covers are easily 

removable and provide ready access to 

the anchorages, they do not qualify as 

vehicle components as provided under 

the proposed provision. 

Global requested clarification on 

whether luggage room boards or covers 

that are readily movable to gain access 

to the tether anchorage are permitted 

under the proposal, and whether such 

covers must be labeled. 

Agency Response 

After careful consideration, this final 

rule allows cargo covers to be present if 

they do not need any tools for removal 

and are marked with a tether marking 

for each tether anchorage available (i.e., 

if there are three tether anchorages 

available under the cargo cover, there 

should be three tether anchorage 

markings). As this cargo cover could be 

removed or relocated away from the 

actual tether anchorage, the anchorage 

must also be marked.108 The agency 

considered not allowing the cargo cover 

feature, but the cargo cover is a 

component that consumers would want 

to use in most cases to hide the cargo 

whenever they do not need to access it 

from the rear seat. Also, because the 

cargo cover does not have sufficient 

structural strength to locate the tether 

anchorage on it, it would not be 

adequate for installing tether 

anchorages. 

Tether Anchorages Located Under the 

Fabric With Slit 

SRN expressed concerns about some 

tether anchorages located on vehicle 

seatbacks and hidden behind the 

seatback fabric. SRN explained that 

although a scored slit in the fabric is 

provided for this design (and in some 

cases, a tether anchorage marking may 


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109See www.cars.com/articles/2014/02/2014- 

land-rover-range-rover-sport-top-tether-trouble-/. 

even be nearby), it is consistently 

difficult for vehicle owners to recognize 

how to access these type of tether 

anchorages. SRN explained it is hard to 

see the slit in low light (such as in a 

garage) and bewildering to owners that 

they would be required to perform this 

step. SRN commented that, because this 

type of hidden tether anchorage 

technically could meet the requirements 

of the proposal, wording should be 

included in the standard that eliminates 

this design option and makes exposing 

the tether anchorage part of the factory 

assembly procedures. 

Agency Response 

In response to SRN’s expressed 

concerns, the proposed requirements 

that ‘‘allow a cap, flap or cover that is 

specifically designed to be opened, 

move aside or to otherwise give access 

to the anchorage’’ would not permit 

such slit access (unless it stays open by 

itself) because it would not expose the 

tether anchorage without obstruction. 

However, in acknowledgement of this 

concern and to provide greater clarity 

and avoid any potential confusion, 

NHTSA is modifying this final rule’s 

regulatory text to ‘‘allow a cap, flap or 

cover that is specifically designed to be 

opened, move aside or to otherwise give 

unobstructed access to the anchorage’’ 

to more explicitly rule out slit designs. 

Tether Anchorages Under Cargo Floor 

Dr. Baer and SRN also commented on 

tether anchorages located below the 

level of the cargo floor (e.g., in the 

Toyota Prius V), explaining that when 

the second-row seating is rolled back to 

the regular passenger seating position, 

the seatback abuts the cargo area floor, 

and the tether anchorages are 

completely out of sight and inaccessible. 

SRN recommended that NHTSA address 

the problem of tether anchorages that 

are inaccessible in certain seating 

locations through an amendment to 

FMVSS No. 225. 

Agency Response 

The proposed requirement to have 

tether anchorages in a location available 

without the need to remove carpet or 

other vehicle components to access the 

anchorages (except for caps, flap or 

covers designed to provide access to the 

anchorage) adequately addresses the 

concerns raised over anchorages 

positioned below the level of the cargo 

floor.109 The agency considers an 

interfering cargo floor as a vehicle 

component that is not providing access 

to the tether anchorage, and therefore 

not meeting the intent of this 

requirement. However, as discussed in 

the previous section, the agency will 

change the regulatory text to ‘‘otherwise 

give unobstructed access to the 

anchorage’’ to more explicitly rule out 

slit designs and obstructed anchorages 

below the cargo floor. 

Tether Strap Over Cargo Area 

Dr. Baer stated that other tether 

anchorage locations include the rear 

wall of the vehicle, which makes it 

impossible to put cargo in the trunk area 

with a tether strap crossing over the 

cargo area. Dr. Baer explained that when 

forced to decide between using a tether 

and having room for cargo, most parents 

will choose the cargo and leave the car 

seat untethered. Therefore, Dr. Baer 

disagreed with NHTSA’s statement that 

‘‘those atypical locations do not appear 

to pose a safety problem.’’ Dr. Baer 

added that while in the crash test lab a 

rear wall tether anchorage is fine, in the 

real world it isn’t practical and simply 

doesn’t get used. 

Agency Response 

Regarding Dr. Baer’s comment on not 

allowing anchorages that interfere with 

cargo space, this is out of the scope of 

this rulemaking, as NHTSA did not 

propose any requirements on this topic 

or how to evaluate interference with 

cargo. 

2. Elimination of the Option To Use a 

Tool or Coin To Remove the Anchorage 

Cover 

The NPRM proposed that a tether 

anchorage must be in a location where 

the anchorage is accessible without the 

need to remove carpet or other vehicle 

components to access the anchorages. 

NHTSA also proposed the anchorage 

must be accessible without the use of 

any tools, including the use of a 

screwdriver or coin. NHTSA clarified 

that a tether anchorage may be covered 

with a cap, flap, or cover, provided that 

the cap, flap, or cover is specifically 

designed to be opened, moved aside, or 

otherwise provide access to the 

anchorage, and it must also be labeled 

with the ISO symbol indicting the 

presence of the tether anchorage 

underneath. 

Comments 

Advocates expressed support for 

improving the regulation regarding 

better access to tether anchorages, 

stating that currently tether anchorages 

must be accessible without the need of 

any tool except a screwdriver or coin 

and anchorages are frequently placed in 

a location requiring consumers to fold 

back a seat or remove camouflage 

coverings such as carpet, seat fabric, or 

a plastic cap. Advocates stated that 

eliminating the need to use a 

screwdriver or coin to access a tether 

anchorage is essential to make CRAS 

anchorages more user-friendly. 

Advocates stated that CRAS anchorages 

intended for use by consumers should 

be user-friendly, and their location 

should be readily apparent when 

needed. 

Agency Response 

The agency received no comments in 

opposition to the proposed requirement 

to require access to the tether 

anchorages without the use of tools, 

including a screwdriver and coin. As 

the agency received comments in 

support of this proposal and new 

vehicle models do not have tether 

anchorages that require a screwdriver or 

a coin to access them, eliminating this 

option is feasible, would incur no cost 

for vehicle manufacturers, and would 

prevent such designs from coming back 

into the fleet. As such, the agency is 

adopting the NPRM’s proposal to 

require access to tether anchorages 

without the use of tools, including a 

screwdriver or coin. The agency will 

also adopt the NPRM’s proposed 

requirement that the tether anchorages 

must be accessible without the need to 

remove carpet or other vehicle 

components to access the anchorage 

(other than marked caps, flaps, or covers 

specifically designed to be opened, 

moved aside, or to otherwise provide 

unobstructed access to the anchorages). 

Marked cargo covers will also be 

allowed as discussed in the previous 

section. 

d. Recognizing the Tether Anchorages 

1. Rigid Bar 

Currently FMVSS No. 225 does not 

provide any material or dimensional 

requirements for tether anchorages, 

other than specifying that the tether 

anchorage must permit the attachment 

of a tether hook meeting the 

configuration and geometry specified in 

figure 11 of Standard No. 213. Most 

vehicle manufacturers use a metal bar 

design for the tether anchorage. These 

metal bars vary in cross section shape; 

some are round, and others are flat. 

However, a few pickup trucks and 

MPVs provide a webbing loop as the 

tether anchorage that can also be used 

as a router to loop the tether through it 

and attach to the tether anchorage in an 

adjacent seat. The webbing loop is so 

different from the conventional metal 

bar design that consumers have 

difficulty identifying them as a router 


ddrumheller on DSK120RN23PROD with RULES3
1314 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

110 Klinich, K.D., Manary, M.A., Malik, L.A., 

Flannagan, C.A.C. ‘‘Tether Anchors in Pickup 

Trucks: Assessing Usability, Labeling, and 

Performance’’ November 2016. https://

deepblue.lib.umich.edu/bitstream/handle/2027.42/ 

156027/UMTRI-2016- 

30.pdf?sequence=1&isAllowed=y. 

111 Illustration can be found on page 10 of FCA’s 

Appendix A submission in Docket No. 

NHTSA2014–0123–0025. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0025. 

and a tether anchorage.110 Also, in some 

cases, the webbing anchorages need to 

be retrieved from another component 

such as a foldable carpet flap that runs 

across the back seat. In certain cases, the 

carpet flap needs to be folded back to 

find the webbing tether anchorage and 

then the webbing needs to be pulled out 

via an object such as a pencil. 

To increase the ease-of-use of tether 

anchorages, NHTSA proposed amending 

FMVSS No. 225 to standardize the 

configuration of the tether anchorage 

such that it is a ‘‘rigid bar of any crosssection shape.’’ One of the main 

objectives of the proposal was to 

increase the standardization of CRAS 

features, to increase consumers’ 

familiarity with the anchorage systems, 

and to increase the ease of using the 

systems, particularly when coupled 

with education efforts that provide a 

simple and uniform message. The 

NPRM stated its belief that having a 

standardized design for the tether 

anchorages such that they can be 

described as a ‘‘rigid bar’’ would help 

consumers easily recognize the 

anchorages in their vehicles and 

facilitate simplified and more effective 

messages in educational materials. 

The NPRM requested comment on 

whether further standardization of the 

tether anchorage should be pursued to 

make the tether anchorage a more 

recognizable vehicle feature. The agency 

tentatively decided not to specify 

dimensions for the tether anchorage to 

give manufacturers some design 

flexibility in meeting FMVSS No. 225’s 

strength requirements. 

General Comments 

Three commenters (UMTRI, 

Advocates, and Dr. Baer) supported the 

standardization of the tether anchorages 

to a rigid bar. UMTRI specifically 

supported prohibiting the use of 

webbing as a vehicle tether anchorage. 

Advocates commented that 

standardizing the tether anchorage will 

allow consumers to identify the device 

and understand its intended use more 

easily. Global supported NHTSA’s 

approach in not specifying the 

dimensions of tether anchorages, as this 

would provide manufacturers design 

flexibility in meeting FMVSS No. 225 

strength requirements. Some 

commenters, including CR, GM, the 

Alliance, FCA, and Global, expressed 

concern regarding eliminating the 

flexible anchorages in certain vehicles. 

These concerns will be discussed in 

detail in the following sections. 

The Alliance stated that because the 

NPRM included the proposed 

requirement for marking all tether 

anchorages with standardized symbols, 

any further standardization is not 

necessary to make the anchorages more 

recognizable. The Alliance further 

stated that there is no data to 

substantiate that the proposed 

requirements standardizing the 

configuration of the tether anchorages 

will increase consumers’ familiarity 

with the anchorage systems and will 

increase the ease of using the systems, 

aside from facilitating simplified 

messages in educational materials. 

Agency Response 

After careful consideration and 

review of comments received, NHTSA is 

adopting the proposed requirements for 

tether anchorages designs to be a ‘‘rigid 

bar of any cross-section shape.’’ 

However, this final rule allows for some 

exceptions to this provision, which are 

discussed in detail below. 

2. Flexible Tether Anchorages for 

Pickup Trucks Versus Foldable Seats 

Pickup Trucks 

FCA commented that several 

proposed requirements within the 

NPRM present technical feasibility 

concerns for pick-up trucks, as the 

inherent architecture of a pick-up truck 

is such that the seats are located near 

the rear of the occupant compartment 

with a glass window directly behind the 

seat.111 FCA explained that taken 

together, the proposals of the rigid bar 

requirement for tether anchorages, 

accessibility without folding the 

seatback, and the minimum distance of 

165 mm from the reference point ‘‘SB,’’ 

make the technical feasibility of the 

design solution even more complex in 

pickup trucks, going against the goal of 

the NPRM. FCA also stated that the 

tentative design solutions to meet all the 

requirements proposed in the NPRM 

would not increase usability of tether 

anchorage and would add unnecessary 

cost and weight to the vehicles. 

The Alliance stated that to meet the 

proposed requirements (rigid tether 

anchorage, no folding of seat to access 

the tether anchorage, and the minimum 

distance of 165 mm from the reference 

point ‘‘SB’’ to the tether anchorage), 

manufacturers would have to include 

seat tracks so that they can move the 

seat forward (instead of folding) to allow 

access to the tether anchorage. Alliance 

added that currently the standard allows 

for designs that provide a folding seat in 

the rear row of a pickup to provide 

access to the tether anchorages. 

GM stated it uses flexible tether 

anchorages made with steel cable in 

conjunction with routers on many of its 

pickup truck models. GM and the 

Alliance explained that the need to use 

routers will increase if access to the 

tether anchor is no longer permitted by 

folding the seatback. 

Agency Response 

After reviewing comments received 

regarding the standardization of the 

tether anchorages as a rigid bar and the 

requirement for tether anchorages to be 

accessible without folding the seat, the 

agency believes flexible tether 

anchorages should be allowed in some 

types of vehicles. The agency 

acknowledges that permitting flexible 

tether anchorages in some vehicle types 

will not achieve the proposed 

standardization of tether anchorages, 

but believes the design challenges 

associated with adding tether 

anchorages on pickup trucks and other 

vehicles where the tether anchorage 

cannot be installed within the tether 

‘‘allowable zone’’ in the required 

standard merits allowing these vehicles 

the option of having flexible tether 

anchorages (that can also be used as 

routing devices). 

Using Flexible Tether Anchorages With 

Routers Versus Accessing Tether 

Anchorages Behind Seatback 

CR expressed concern about the 

elimination of the adjacent routing 

option for tethers in pickup trucks. CR 

acknowledged that the adjacent loop 

method of attaching the tethers in 

pickup trucks is different and less 

intuitive than in most other vehicles; 

however, CR stated that based on 

evaluations of tether anchorage access 

in pickups prior to the availability of the 

adjacent routing technique, it was still 

a preferable alternative to some of the 

more hidden tether anchorage locations 

behind a folding seatback. CR stated 

these alternate locations create a unique 

imbalance when installing a forwardfacing seat between holding the seat and 

accessing the tether anchorage. 

Similarly, GM relayed feedback it 

received from child passenger safety 

technicians (CPST) regarding the 

flexible cable tether anchorage versus 

rigid anchorage located behind a folding 

seatback. Feedback received stated that 

while it may take some familiarity or 

consultation with the owner’s manual, 


ddrumheller on DSK120RN23PROD with RULES3
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1315 

112 Illustration can be found on page 13 of FCA’s 

Appendix A submission in Docket No. NHTSA 

2014–0123–0025. Link: www.regulations.gov/ 

document/NHTSA-2014-0123-0025. 

113 Illustration can be found on page 11 of 

Alliance comment submission in Docket No. 

NHTSA2014–0123–0027. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0027. 

114 Illustration can be found on page 12 of FCA’s 

Appendix A submission in Docket No. 

NHTSA2014–0123–0025. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0025. 

once a user understands how to route 

and attach the tether using the flexible 

routers it is easier to do than it is to fold 

the seat forward to access a rigid 

anchorage on the back of the seat or cab 

wall, attach the tether, fold the seatback 

upright, and then install the CRS and 

tighten the tether strap. GM opined that 

it is no more complicated or confusing 

to attach the tether hook to a flexible 

cable-type anchorage than to a separate 

rigid anchorage in situations where use 

of a router is required. 

FCA 112 submitted current designs 

with webbing straps, located behind 

each seating position, that serve as both 

the tether strap routing device and the 

tether anchorage. FCA explained that 

when a child restraint is installed in a 

seating position, the tether strap for the 

child restraint is routed through the 

routing device behind the seating 

position in which the child restraint is 

installed and the tether hook is then 

attached to the strap in the adjacent 

seating position. FCA stated that it 

provides clear installation instructions 

in the owner’s manual to explain the 

correct child restraint installation 

procedure and that due to the flexibility 

of the strap on the vehicle, it is quite 

easy to attach the tether hook to the 

tether anchorage. FCA pointed out that 

due to the proposed NPRM requirement 

that the tether anchorage be a rigid bar, 

this design will no longer be allowed. 

Agency Response 

Following careful consideration of 

comments received, NHTSA agrees with 

CU, GM, and FCA that flexible tether 

anchorages that can also be used as 

routers are easier to use than tether 

anchorages located behind a folding 

seatback. While the tethering method of 

looping the tether strap through the 

routing device and attaching it to a 

tether anchorage (also a routing device) 

of an adjacent seating position is not 

intuitive at first, once the method is 

known it is easily understood and easily 

performed. Therefore, flexible tether 

anchorages will continue to be allowed 

in some vehicles. 

Request To Allow Folding Seat To 

Access Tether Anchorage 

Global requested that the agency 

allow the folding of seatbacks to access 

the tether anchorage in pickup trucks 

where no practical alternative exists to 

locate the tether anchorage. 

The Alliance stated that packaging 

space in single row vehicles (discussed 

in the next section) and in pickup trucks 

is often limited and seats are often 

located near the rear of the occupant 

compartment. The Alliance added that 

locations for tether anchorages are 

regulated in the current FMVSS No. 225 

and need to have suitable vehicle 

structure to manage the forces of the 

child restraint in a crash. The Alliance 

elaborated that one solution often found 

in sports coupes and pickup trucks is to 

locate the tether anchorage on the 

vehicle body where loads can be 

managed, behind the passenger seat.113

The Alliance stated that access to the 

anchorage requires the seat to be moved 

or tilted forward to attach the tether 

hook to the anchorage and that once the 

hook is engaged, the seatback is moved 

backward to a locked position and the 

tether strap is tightened. The Alliance 

explained that, as currently proposed in 

the NPRM, the tether anchorages would 

likely need to be relocated to the 

vehicle’s body and that the relocated 

anchorage would require the addition of 

a tether routing loop behind the head 

restraint. 

Agency Response 

The agency has decided not to allow 

seats to be folded to reach the tether 

anchorages in pickup trucks because it 

is more difficult to install a CRS using 

this method, as it may require an 

iterative installation process to achieve 

the desired tight installation. Pickup 

truck designs that require the vehicle 

seatback to be folded to access the tether 

anchorages can be modified to include 

flexible tether anchorages (that can be 

used as routing devices). Some of these 

pickup designs may already have 

enough structure to handle the tether 

loads if changed to a flexible tether 

anchorage design, although some may 

have to be reinforced. 

Based on comments and inspections 

performed by the agency, pickup trucks 

that do not use the flexible tether 

anchor/routing device have a foldable 

seatback that allows access to a rigid 

tether anchorage in the seatback in the 

back wall or floor of the pickup. 

Additionally, in some pickup trucks, 

depending on the design of the CRS 

tether hardware, the hardware can 

prevent the seatback from latching, 

which could cause consumers to not use 

the tether at all. 

While the agency acknowledges 

Global and the Alliance’s comments that 

some pickup trucks should be permitted 

to have folding rear seats to access 

anchorages, as no practical alternative 

exists to locate them, we respectfully 

disagree with this view. Although 

certain pickup trucks may require some 

modifications to meet the requirements 

of this final rule, pickup trucks that 

have folding rear seats should be able to 

accommodate the routing/tether 

anchorage design. Further, this design 

should not interfere with vehicle 

models that have moving or foldable 

backs to access other elements such as 

storage or tools. 

Reduced Rear Seat Space if Other 

Solutions Are Not Allowed 

FCA stated that because the NPRM 

proposal does not allow for flexible 

tether anchorages and folding the 

seatback to access the tether anchorage 

space behind the seat, accessible tether 

anchorages would come at the expense 

of passenger space in the rear seat to 

meet the proposed requirements. FCA 

stated that reducing the space behind 

the front seat is counterproductive to 

the overall goal of fitting children in 

child restraints in the back seat of 

vehicles, including pickup trucks. 

Agency Response 

Since this final rule permits flexible 

anchorages and routers, manufacturers 

should not have to choose to include 

seat tracks to move the seat forward or 

to reduce the rear seat space to access 

the tether anchorage without folding the 

seatback. We agree that reducing the 

rear seat space to create an accessible 

tether anchorage would be 

counterproductive to helping fit CRSs in 

the rear seat. 

Conflicts With FMVSS No. 202 

FCA stated that other regulations such 

as FMVSS No. 202a can be in direct 

conflict with the changes proposed in 

the NPRM because they can impede the 

access to the tether anchorage even 

further.114 FCA stated the proposed 

rigid bar requirement for tether 

anchorages, accessibility without 

folding the seatback, and the minimum 

distance of 165 mm from the reference 

point SB make the technical feasibility 

of the design solution even more 

complex, as the head restraint would 

block access to the rigid tether 

anchorage and the head restraint could 

not be folded, as the folding the 

seatback is assumed to not be allowed. 

Agency Response 

Continuing to allow the flexible 

anchorage with router design should 


ddrumheller on DSK120RN23PROD with RULES3
1316 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

115 Illustration can be found on page 9 of FCA’s 

Appendix A submission in Docket No. 

NHTSA2014–0123–0025. Link: 

www.regulations.gov/document/NHTSA-2014-0123- 

0025. 

eliminate the concerns expressed by 

FCA in relation to any potential conflict 

with the new tether location 

requirements (see section above VI.b.1), 

the restriction of folding the seatback to 

access the tether anchorage, and having 

to place the tether anchorages in 

locations that will allow tightening of 

the tether. The cost to implement the 

routing device/tether anchorage designs 

should be low, as most pickup trucks 

already have such designs. Further, per 

this final rule, flexible anchorages and 

routers will be allowed in vehicles 

where no part of the shaded tether 

anchorage zone in the standard is 

accessible without folding the seat or 

removing a seating component of the 

vehicle (per S6.2.1.1 of FMVSS No. 

225). Head restraints will also be 

allowed to be moved/folded or removed 

to provide better access to the 

anchorages. 

Conflicts With Canadian Standard 

The Alliance stated that if NHTSA 

revised S6.2(b)(1) as proposed it would 

create a dilemma if CMVSS 210.1 is not 

similarly revised, since most or all 

manufacturers of these vehicles also sell 

these vehicles in Canada. 

Agency Response 

The requirements adopted by this 

final rule continue to allow flexible 

tether anchorages with routers for 

vehicles that cannot locate the tether 

anchorage in the ‘‘allowed zone.’’ 

Therefore, these requirements do not 

conflict with Canada’s standard. 

Labeling Instead of Vehicle 

Modifications 

The Alliance recommended NHTSA 

require a label on the top/side of the 

seatback (facing toward the door) 

directing consumers to the presence of 

the tether anchorage behind the 

seatback to prevent costly vehicle 

modifications. The Alliance stated that 

this requirement would allow tether 

anchorages to remain in relatively 

accessible and expected locations in 

these vehicles. 

Agency Response 

NHTSA disagrees with the Alliance’s 

suggestion to require a label on the 

seatback to direct consumers to the 

tether anchorage behind the seatback, as 

such a label would not solve the 

difficulties in tightening the tether when 

it is located behind the seat, or the 

inability to re-latch the seatback due to 

interference with certain CRS tether 

hardware. NHTSA also does not have 

information on the effectiveness of such 

a label, and it falls outside the scope of 

this rulemaking. 

3. Single Row Vehicles 

FCA stated that packaging space in 

single row vehicles is very limited, with 

seats often located near the rear of the 

occupant compartment. FCA explained 

that because the location for the tether 

anchorage needs to have a suitable 

structure to manage the forces in a 

collision, tether anchorages are often 

located on the structure behind the 

passenger seat. FCA added that access to 

such tether anchorage requires the 

seatback to be moved or tilted forward 

to attach the tether hook to the tether 

anchorage, and that once the hook is 

engaged, the seat is returned to its 

normal driving position and the tether 

strap is tightened.115

FCA described two of its single row 

vehicles, the Dodge Viper, and the 

Alpha 4C, which require the user to fold 

the front passenger seatback forward to 

gain access to the tether anchorage 

located on the vehicle structure directly 

behind the passenger seat. FCA stated 

there are limited engineering solutions 

available capable of withstanding the 

forces required by FMVSS No. 225 in 

both vehicles, and recommended 

NHTSA continue to allow the folding of 

the seatback to gain access to tether 

anchorages installed in single row 

vehicles. 

Agency Response 

NHTSA disagrees with FCA’s 

expressed concern regarding access of 

tether anchorages for single row 

vehicles and this final rule will not 

permit the folding of the seatback to 

access the tether anchorage. Pickup 

trucks also have a challenging geometry 

and have been able to accommodate 

tether anchorages with routing devices. 

NHTSA acknowledges single row 

vehicles face similar challenges where 

no part of the shaded tether anchorage 

zone in the standard is accessible 

without removing a seating component 

of the vehicle or folding the seat-back 

forward. However, as discussed earlier 

in this section, vehicles with these 

characteristics will be allowed to 

accommodate routing devices to avoid 

folding the seatback to access the tether 

anchorages. CRS installation is easier 

using routing devices for attaching the 

tether-to-tether anchorages than CRS 

installation involving folding the 

seatback to access the tether anchorage, 

because such an installation would be 

an iterative process for tightening the 

tether or, depending on the CRS tether 

hardware design, could create a 

condition where the seatback cannot be 

re-latched, resulting in consumers not 

using the tether at all. As previously 

stated, this final rule will permit flexible 

anchorages and routers in vehicles 

where no part of the shaded tether 

anchorage zone in the standard is 

accessible without folding the seat or 

removing a seating component of the 

vehicle. Further, head restraints will be 

allowed to be moved/folded or removed 

to provide better access to the 

anchorages. This allowance should 

alleviate the aforementioned concerns 

raised by FCA. 

4. Buses With a GVWR of 10,000 

Pounds or Less 

GM requested that buses under 10,000 

pounds gross vehicle weight (i.e., 12 and 

15 passenger vans) be exempt from the 

requirement that the tether anchorages 

be a rigid bar. GM pointed out that 

school buses are already exempt 

altogether from requirements to provide 

any tether anchorages. GM explained 

that the 12–15 passenger van segment is 

a very small (much less than 1 percent 

of total market sales) specialized 

segment of vehicles which are typically 

driven by employees or individuals 

affiliated with a business or 

organization. GM provided figure 5 

below showing the metal anchorage in 

these vehicles is attached to a flexible 

strap which is bolted to the lower seat 

structure. GM also noted that the seats 

in these vehicles have a single seatback 

shared by 3 or 4 seating positions and 

that these seats are already quite heavy 

and would become even heavier if 

additional structures were added to it to 

handle CRS tether loading. GM 

explained that today, as marked, these 

anchorages are readily recognizable and 

easy to use. GM recommended allowing 

flexible strap tether anchorages for bus 

applications. 


ddrumheller on DSK120RN23PROD with RULES3
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1317 

116 Jermakian J.S., Klinich K.D., Orton N.R., 

Flannagan C.A.C., Manary M.A., Malik L.A., 

Narayanaswamy P. 2014. Factors affecting tether 

use and correct use in child restraint installations. 

J Safety Res 51:99–108. 

Agency Response 

NHTSA agrees that there is merit to 

GM’s request to permit flexible tether 

anchorages on buses with a gross 

vehicle weight of 10,000 pounds or less. 

Requiring rigid anchorages in these 

types of vehicles may increase the 

weight of the vehicle when adding 

structures for the rigid anchorages. This 

is an important concern as vehicles are 

only required to provide 3 tether 

anchorages, and added weight might 

deter manufacturers from continuing to 

provide additional tether anchorages in 

these types of vehicles. The agency will 

therefore exclude buses with a GVWR of 

10,000 pounds or less from the 

requirement for rigid tether anchorages. 

VII. Conspicuity and Identification of 

Vehicle Anchorages and CRS 

Connectors 

NHTSA proposed to amend FMVSS 

No. 225 to require all vehicles to bear 

the ISO standardized markings 

developed by ISO’s voluntary standard 

near all lower anchorages and tether 

anchorages provided in the vehicle to 

improve the ease with which consumers 

find lower anchorages and tether 

anchorages in the vehicle. The agency 

also proposed requiring the same ISO 

markings on CRS lower anchorage 

connectors and on tether hooks. The 

agency proposed that the lower 

anchorage connector marks must be at 

least 9 mm (0.35 in) in diameter. 

Further, the NPRM proposed that the 

markings on the tether anchorage 

connector must be on the tether strap or 

a tag attached to the strap, and that the 

marking must be located within one 

inch of the tether hardware assembly 

(tether hook and adjustment hardware). 

The proposal also stipulated that the 

tether anchorage connector markings 

must be at least 8 mm (0.35 in) in 

height. 

NHTSA also proposed that both 

vehicle and CRS manufacturers must 

include an explanation of the meaning 

of the markings in the vehicle manual 

to make consumers more aware of the 

existence of CRASs and to facilitate 

consumer education efforts by 

simplifying education messages. 

Currently, the ISO voluntary standard 

has two different tether anchorage 

symbols and under the agency’s 

proposal CRS manufacturers and 

vehicle manufacturers would have the 

option of using either marking. 

a. General Comments and Agency 

Responses 

1. General Support for Markings and 

Manuals Requirements for Vehicle and 

CRSs 

Several commenters expressed 

support for the proposed standardized 

ISO markings on all child restraint 

anchorages and the child restraint 

anchorage connectors. Two 

commenters, IIHS and Dorel, also stated 

they supported the proposed language 

requirements for the vehicle and child 

restraints manuals. IIHS and Dr. Baer 

agreed that the standardized symbols 

and presence of markings will help 

simplify educational messaging to 

parents. 

Britax commented that consumers are 

reluctant to review vehicle owner’s 

manuals to determine tether anchorage 

locations and that they have witnessed 

consumers attaching the tether to nontether anchorage points. Britax further 

stated that making vehicle tether 

anchorages more visible and 

consistently marked should improve 

and encourage tether usage. Similarly, 

Advocates stated that a common error in 

properly installing a CRS is the 

attachment of the tether to a device that 

is in fact not a tether anchorage. 

Advocates explained that requiring a 

standard symbol at the location of each 

tether anchorage, regardless of whether 

the anchorage is visible, will assist 

consumers in not only properly 

installing a CRS but increasing 

awareness of the existence of these 

devices. Advocates commented that 

instituting uniformity in markings by 

requiring a standard symbol already 

used by the International 

Standardization Organization (ISO) and 

adopted by a majority of vehicle 

manufacturers will further assist 

consumers in identifying both the lower 

anchorages and tether anchorages. 

Agency Response 

Following review of comments 

received, the agency has decided to 

adopt the proposed lower anchorage 

and tether anchorage markings, as well 

as the proposed markings for CRS lower 

anchorage connectors and tethers. The 

agency received widespread support for 

the markings, although some 

commenters had concerns with the 

restrictive locations of the markings 

with respect to the anchorages, the 

symbols required, and some vehicles 

that have specific challenges such as 

pickups and hatchbacks that may have 

an open trunk. The following section 

further discusses the issues raised by 

the commenters regarding the proposed 

requirements for anchorage marking 

location and design, NHTSA’s decision 

on the issues, and the final rule 

requirements. 

2. Marking Contrast and Color Coding 

IIHS and Dr. Baer supported the 

proposed improved labeling to identify 

tether anchorages but stated that a color 

contrast requirement for the label 

should be incorporated in the standard. 

IIHS stated that labeling itself was not 

associated with tether use in its 

study,116 explaining that this result may 

be because the embossed labels that are 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.030</GPH>

Figure 5. Chevrolet Express Tether Anchorage 
1318 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

117FMVSS No. 209, S5.1. 

118ECE R.44, ‘‘Restraining devices for child 

occupants of power driven vehicles (Child restraint 

systems),’’ www.unece.org/fileadmin/DAM/trans/ 

main/wp29/wp29regs/2015/r44r3e.pdf. 

119ECE R.129, ‘‘Uniform provisions concerning 

the approval of enhanced child restraint systems 

used on board vehicles (ECRS),’’ www.unece.org/ 

fileadmin/DAM/trans/main/wp29/wp29regs/2013/ 

R129e.pdf. 

frequently used are often difficult to see. 

Similarly, SRN and Dr. Baer stated that 

some tether anchorage markings 

currently in vehicles are extremely 

difficult to see, even in daylight 

conditions, because the marks are 

engraved into dark plastic. SRN stated 

that the tether anchorage markings will 

only accomplish the intended goal if 

they are easily visible. 

Advocates stated that during the 2007 

public meeting they urged NHTSA to 

require all tethers anchorages and lower 

anchorages to be conspicuously marked. 

Advocates added that the 2006 Decina 

study, supra, revealed that the majority 

of consumers who did not use lower 

anchorages (55 percent) reported that 

they did not use them partly because 

they could not find them or did not 

know where they were located in the 

vehicle. Advocates stated that while it 

would be optimal to have all persons 

who install add-on CRSs be fully 

acquainted with the FMVSS No. 225 

CRAS, a portion (if not a majority) of the 

public will not be fully conversant and 

informed regarding the CRAS. 

Advocates stated that requiring 

anchorages and connectors that are 

color-coded or otherwise conspicuous, 

and that obviously match the CRS 

anchorages or connectors, is one way to 

provide intuitive cues that can lead to 

increased rates of proper installation 

even among those members of the 

public who are not fully conversant 

with technical details and requirements 

of FMVSS No. 225. Dr. Baer supported 

the markings on CRS lower connectors 

and tethers but suggested that vehicle 

and CRS manufacturers should be 

required to use a specific color on the 

symbol to help parents match the colors 

in addition to the symbol. 

Graco requested clarification on (1) 

whether the proposed marking on the 

CRS lower anchorage and tether 

anchorage connectors can be embossed 

or engraved (i.e., molded in plastic or 

stamped in steel), (2) whether the 

required markings can, but do not have 

to be, color contrasting, (3) whether the 

pictogram for lower anchorages can be 

on a tag or if it must be in the connector, 

and (4) whether the pictogram on figure 

16 in the NPRM is permitted on an 

attached tag that is located 25 mm, 

measured from the shortest distance 

from the nearest edge of the pictogram, 

to the tether hardware. Dorel agreed that 

if the marking is on the tether strap or 

a tag attached to the strap, the marking 

must be located within one inch of the 

tether hardware assembly (tether hook 

and adjustment hardware). 

Agency Response 

NHTSA acknowledges the suggestion 

raised by several commenters that the 

proposed vehicle markings should have 

contrast or even color coding. However, 

the agency is declining to include color 

coding requirements in the markings for 

this final rule, as this specific issue is 

outside of the scope of this final rule 

since the NPRM did not propose any 

color contrast or color coding on the 

markings. Further, NHTSA does not 

have data on the incremental benefit of 

having contrast and/or color coding in 

the markings; this determination would 

require evaluation of whether contrast/ 

color markings result in more correct 

installations than markings without 

color contrast. However, NHTSA 

encourages manufacturers to make the 

markings as visible as possible, 

including via contrast and/or color to 

further improve the usability of the 

equipment. Similarly, the CRS 

connectors will not be required, but will 

be allowed, to have color contrast. 

For the markings on the CRS 

connectors, Graco requested 

clarification on whether the proposed 

marking on the CRS lower anchorage 

and tether anchorage connectors may be 

embossed or engraved (i.e., molded in 

plastic or stamped in steel). The 

proposed FMVSS No. 225 does not have 

any requirements on how the marking is 

fabricated; therefore, molded plastic, 

stamped in steel, and other methods are 

allowed as long as the location and size 

of the required marking requirements 

are met. As certain methods of marking 

could be applied to webbing, 

manufacturers are reminded that 

component requirements of FMVSS No. 

213, e.g., webbing breaking strength,117

are subject to compliance testing with 

the marking included, if it is present on 

the sample to be tested. 

Further, although the proposal did not 

explicitly permit the lower anchorage 

connector mark to be on a tag, the 

option of having the marking on the 

connector itself or a tag located 25 mm 

(similar to the proposal for the tether 

anchorage connector tag) from the 

connector is beneficial, as some 

connectors (hook-type) may have more 

difficulties accommodating the symbol. 

As such, in response to Graco’s 

comment, NHTSA is permitting the 

pictogram to be located on a tag that is 

25 mm from the connector. This 

measurement will be made from the 

nearest part of the connector (plastic/ 

metal part not webbing) to the tag with 

the tether symbol. 

b. Lower Anchorage Marking Comments 

and Agency Responses 

1. Lower Anchorages I-Size, ISOFIX and 

Other Text in Symbols 

MEMA urged NHTSA to consider 

allowing the use of other existing 

marking designs used in ISOFIX and iSize labels (figure 6), which are widely 

used in the industry in many markets. 

MEMA explained that consistency of 

markings is critical for its global 

company members that supply to global 

vehicle manufacturers. MEMA added 

that the small differences between the 

agency’s proposed markings and those 

already in use would result in 

redesigning and changing component 

production to feature the different 

symbols, which adds cost and burden 

for manufacturers. 

MEMA added that, depending on the 

overall design, the surrounding shape of 

the symbol may not always take the 

form of a circle or sphere. Although the 

agency did not propose any changes to 

the marking shape language in the 

current standard, MEMA suggested the 

agency consider permitting other shapes 

to enclose the symbol as the United 

Nations Economic Commission for 

Europe (ECE) regulations do permit ISO 

or iSize symbols/labels. Similarly, the 

Alliance stated that parts of ECE 

Regulation 44 118 are incorporated into 

the new UN R–129 119 with new size 

and functional performance criteria, and 

that the new CRS will be marked as isize-ready. The Alliance explained that 

in order to guarantee the fitment of 

these CRSs in the vehicle, original 

equipment manufacturers must fulfill 

requirements in addition to those 

currently in ECE R14 and R16. The 

Alliance added that if seating positions 

fulfill the new i-Size option of ECE R14 

and R16, they may be marked as an ‘‘iSize seating position’’ with the i-sizesymbol (square) replacing the ISOsymbol (round). MEMA urged NHTSA 

to clarify the marking location to allow 

the symbol to appear within other 

shapes, and to consider harmonization 

with ECE label requirements. 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1319 

120The proposed FMVSS No. 213 side impact 

protection was later adopted as FMVSS No. 213aSide Impact Protection. 

MEMA added that NHTSA’s proposed 

language appears to only allow for the 

use of a single symbol as depicted in the 

NPRM, which is a much narrower 

requirement than the current regulation 

that allows for words, symbols, and 

pictograms. MEMA raises this issue 

because the ISO standard symbol, in 

some cases, may include the term 

‘‘ISOFIX’’ or ‘‘i’’ near the symbol. 

MEMA urged NHTSA to allow text to be 

either inside or adjacent to the ISO 

standard pictogram symbol (indicating 

such allowances in the notes associated 

with the attributed figure/symbol) and 

to consider harmonization with ECE 

label requirements. 

The Alliance stated that one element 

of the i-Size option in European 

regulation (ECE R14 and R16) is the 

support leg installation assessment. The 

Alliance relayed that some rear-facing 

infant child restraints have introduced 

this feature and more, (including 

forward-facing restraints) may follow as 

the newly proposed FMVSS No. 213 

side impact requirements 120 become 

effective. The Alliance stated that 

vehicle manufacturers have already 

received questions regarding the use of 

these types of seats for installation 

purposes and that a vehicle 

manufacturer could potentially indicate, 

with the placement of the new square 

symbol, that its floor design will uphold 

use of a support leg. 

The Alliance added that when 

comparing both ISO and i-Size symbols, 

the i-Size symbol could even encourage 

the user to check the owner’s manual 

since ‘‘I,’’ in general ISO terms, is the 

symbol for ‘‘information.’’ The Alliance 

suggested that as long as the symbol’s 

meaning is explained in the owner’s 

manual, either the ISO or i-Size symbols 

should be permitted to identify the 

lower anchorages in the vehicle. 

Agency Response 

MEMA and the Alliance requested 

allowing both the ‘‘i-size’’ marking and 

the ISO lower anchorage marking, as 

they are very similar (instead of a circle, 

the ‘‘i-size’’ marking is a rounded square 

and has a letter ‘‘i’’ in the marking), and 

that doing so would help harmonization 

efforts. The Alliance stated that if the 

vehicle had an ‘‘i-size’’ symbol the 

consumer would be able to recognize 

vehicles where they can use CRSs with 

support legs or that the ‘‘i’’ could be 

used as an ‘‘information’’ icon so that 

the consumer looks in the vehicle’s 

manual. 

Following careful consideration, this 

final rule does not allow for the use of 

the i-size marking. Since ‘‘i-size’’ 

requirements are not in U.S. standards, 

the U.S. cannot verify that anchorages 

marked with the ‘‘i-size’’ symbol meet 

the corresponding European ‘‘i-size’’ 

requirements. This means that NHTSA 

could not ensure that the vehicle would 

accommodate a CRS with a support leg. 

Further, the agency could not ensure 

that vehicle manufacturers would 

consistently use an ‘‘i-size’’ symbol only 

when vehicles do meet the European ‘‘isize’’ requirements. NHTSA is also not 

persuaded that the ‘‘i’’ in ‘‘i-size’’ could 

be used as an information icon, which 

would be inconsistent with the meaning 

of ’’i-size’’. 

This final rule does allow the term 

‘‘ISOFIX’’ to be displayed near, but not 

instead of, the new required symbol. 

This is because the ISOFIX standard is 

more aligned with U.S. standards and 

the term has been used for the lower 

anchorages in the U.S. market for many 

years. 

2. Lower Anchorage Markings 

Tolerances 

MEMA stated that adding markings to 

visible lower anchorages may require 

trim design changes and redesign to 

meet the proposed requirements. MEMA 

commented that seat designs with a 

visible lower anchorage would not be 

able to accommodate a marking placed 

in the existing 50 mm zone. MEMA 

explained that because some seat 

designs have trim seams running 

vertically through the 50 mm zone, the 

button markings are offset from the 

seams, making it challenging to have the 

marking within the compliance zone. 

MEMA added that other designs have 

the seat-cushion bight line within the 

marking zone, making it difficult to 

package the marking and meet the 

proposed dimensional capability. 

MEMA stated that the industry solution 

for this difficulty has been to make the 

lower anchorage wire visible. 

MEMA stated the proposed 

requirement to add markings to visible 

lower anchorages may not have a safety 

implication, but might have a quality 

implication on the trim. Thus, MEMA 

urged NHTSA to reconsider the need to 

mark visible lower anchorage wires. In 

the alternative, at minimum, MEMA 

requested that NHTSA expand the 

compliance zone dimensions to 

accommodate seat trim design elements. 

MEMA recommended increasing the 

lower anchorages’ vertical zone to 25 to 

125 mm and the horizontal zone to ±50 

mm from the centerline of the wire. 

MEMA stated that these increased 

tolerances will help marking visibility, 

keep the marking within compliance, 

and avoid potential redesign of seating 

function/design elements. MEMA also 

requested clarification on S9.5(a) of the 

current regulation, which reads: ‘‘Above 

each bar installed pursuant to S4, the 

vehicle shall be permanently marked 

with a circle.’’ MEMA asked for 

clarification on the ‘‘above,’’ as there are 

cases where the latch wires are 

positioned higher than at the seat bight, 

meaning that the label may not be 

situated above the latch wire, but in 

front of it. 

SRN agreed with the proposals related 

to the ability to identify anchorages and 

recommended a requirement that the 

lower anchorage markings be placed on 

the vehicle seatback cushion in an area 

above the lower anchorages. SRN 

explained that this recommendation 

would allow for consistent usage 

verbiage to describe searching below the 

mark. SRN added that although nearly 

all current markings comply with this 

suggestion, there are exceptions in 

which the marking is placed below the 

lower anchorage bar on the vehicle seat 

cushion. 

Agency Response 

The agency disagrees that markings 

should not be required for visible 

anchorages, which would not 

accomplish the standardization the 

agency is seeking. The current standard 

allows for the marking of the lower 

anchorages to be on a tag, and 


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Figure 6. ISO and i-Size Symbols 
1320 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

manufacturers could use this method if 

vertical seams do not allow for the 

positioning of a button-type marking 

centered ±25 mm with the anchorage. 

The agency also disagrees with the 

suggestion that the standard should 

increase the allowable vertical zone for 

the marking from 50–100 mm to 25–125 

mm and the horizontal zone from +100 

mm (forward) to ±50 mm. Specifically, 

a 25 mm (vertical) distance above the 

lower anchorages may be too small, as 

the contour of the seat may position the 

marking downwards, making it difficult 

for a customer to see. Additionally, a 

125 mm distance may be too far away 

from the lower anchorage to be able to 

identify the correct equipment. 

However, NHTSA does agree that the 

horizontal zone should be expanded to 

accommodate seat contours where the 

marking would be positioned behind 

the anchorage when a visible anchorage 

is more forward. Therefore, NHTSA is 

expanding the allowable horizontal 

zone for marking from +100 to ¥50 mm 

(see figure 7) for this final rule. 

Given the additional lead time 

provided by this final rule, 

manufacturers should be able to make 

any necessary adjustments to their trim 

design to enable them to always have 

the lower anchorage marking above the 

lower anchorage in all vehicles, whether 

they are visible or not. 

In response to the request for 

clarification on S9.5.1(a), NHTSA agrees 

that the word ‘‘above’’ could cause 

confusion, as S9.5(a)(3) specifies the 

allowable location of the marking which 

can be above, or in front of, the lower 

anchorage. Therefore, this final rule will 

delete the word ‘‘Above’’ from section 

S9.5.1(a) to avoid any confusion. 

In response to the comment that the 

lower anchorages’ markings should be 

placed above the lower anchorages 

based on SRN’s finding that while most 

vehicles have the marking above, some 

manufacturers place it below the lower 

anchorage bar, NHTSA points out that 

the current FMVSS No. 225 requires the 

marking to be on the seatback area 

between 50 and 100 mm above the 

anchorage or on the seat cushion 100 

±25 mm forward, as illustrated in figure 

22 of FMVSS No. 225 (which will be 

slightly changed to accommodate visible 

lower anchorages in this final rule). The 

marking also must be centered with the 

center of the bar (±25 mm). Given 

differences in seat, anchorage, and seat 

designs, we believe having the marking 

centered with the anchorages along the 

seatback or seat cushion is sufficient to 

identify the lower anchorage. 

Additionally, as the agency did not 

propose removing the already allowed 

area for the marking on the seat cushion, 

additional restrictions on this area 

would be outside the scope of this 

rulemaking. 

3. Lower Anchorage Tag With Weight 

Limit 

Britax suggested that the agency 

consider requiring ‘‘acknowledgment’’ 

of the load limits of the lower 

anchorages with a flag tag or vehicle 

seat label consistent with the recent 

revisions to FMVSS No. 213, which 

restricts use of the lower anchorages to 

the child weight limit of 29.5 kg (65 lb) 

minus the CRS weight. Britax explained 

that currently this weight restriction is 

indicated on labels on the child 

restraint, but that also providing lower 

anchorage flag tags or vehicle seat labels 

instructing the consumer to check their 

vehicle owner’s manual would reduce 

the opportunity for misuse and remind 

consumers that the use of lower 

anchorages is weight limited. 

Agency Response 

NHTSA does not believe requiring a 

label with a weight limit identified on 

the lower anchorage markings will help 

consumers or promote ease-of-use, as 

the child weight limit required on the 

CRS label is specific to each CRS. 

Therefore, vehicle manufacturers cannot 

calculate the child weight limit specific 

to each CRS to use with the lower 

anchorages to install a CRS. In fact, a 

label on the lower anchorages with the 

combined allowable weight of the CRS 

and child could confuse the consumer, 

because they would have to determine 

the CRS weight, calculate the allowable 

child weight, and then compare it to the 

CRS label, which may not match in 

many cases. As such, this final rule will 

not require a label with a weight limit 

identified on the lower anchorage 

markings. 

4. Tether Anchorage and Connector 

Marking Size Height vs. Diameter 

MEMA commented that the reference 

to the figure 25 pictogram in the NPRM 

indicated that the tether anchorage 

cannot be less than 20 mm in diameter, 

but pointed out that the figure itself 

actually shows a height of 20 mm, rather 

than a diameter. MEMA expressed 

concern that the 20 mm diameter on the 

tether anchorage may not include the 

entire pictogram for some applications 

(depending on the function/design of 

the tether anchorage component); 

therefore, MEMA urged NHTSA to 

revise the regulatory text to refer to a 

height, rather than a diameter. 

Similarly, Global, GM, and the 

Alliance stated that given the manner in 

which the pictogram measurement is 

shown in figure 25 of the proposed 


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Figure 7. FMVSS No. 225 Figure 22 (left) and Updated FMVSS No. 225 Figure 22 (right) 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1321 

121As illustrated in figure 17 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

122As illustrated in figure 18 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

regulatory text, along with the irregular 

shape of the pictogram, the 20 mm 

criterion can more appropriately be 

described as ‘‘height,’’ rather than 

‘‘diameter.’’ Finally, the Alliance stated 

that the ‘‘circle’’ referred to in the last 

line of 9.5.2(b) means a ‘‘symbol’’ in 

figure 25, and should be referenced as 

such in the regulatory text. 

Agency Response 

NHTSA agrees with the 

aforementioned comments expressing 

concerns over the reference to the 

diameter, rather than the height, in 

relation to figure 25 of the NPRM, and 

is correcting the proposed regulatory 

text in response to these comments. As 

such, this final rule will state that the 

tether anchorage marking cannot be less 

than 20 mm in height. NHTSA also 

agrees with the Alliance’s statement that 

the ‘‘circle’’ referred to in the last line 

of 9.5.2(b) means a ‘‘symbol’’ in figure 

25 of the NPRM, and this final rule will 

reference the marking as a symbol 

instead of a circle for clarification 

purposes. 

c. Tether Anchorage and Connector 

Marking Comments and Agency 

Responses 

Tether Anchorage and Connector ISO 

Symbols 

In response to the proposal to use 

either of the two ISO symbols to mark 

child restraint tether anchorages and 

connectors, Dorel commented that with 

the introduction of CRASs it adopted 

the same standardized ISO symbol 

marking of child restraint anchorage 

connectors to harmonize and improve 

the ease-of-use of CRASs. Dorel added 

that child restraint manufacturers would 

have the option of using either marking. 

The Alliance stated that either of two 

ISO labeling tether symbols may be 

used. 

In contrast, SRN and UMTRI stated it 

would be better to choose a single ISO 

tether anchorage symbol to mark the 

tether anchorages and connectors to 

reduce any confusion that may arise 

from the different symbols. SRN stated 

it was unaware of the original reason for 

ISO developing two similar symbols or 

whether having two symbols serves an 

ongoing purpose. SRN also stated that 

the two designs do not have a 

purposeful difference. 

Agency Response 

The agency received comments in 

support of and in opposition to 

standardizing the two tether anchorage 

markings currently available in the ISO 

standard (figure 8). NHTSA believes the 

symbols are sufficiently similar for 

consumers to recognize either of them; 

therefore, the agency will allow either 

ISO symbol to be used, rather than 

selecting only one permitted symbol for 

use. Although the agency has not done 

an analysis on whether one symbol is 

more easily understood by consumers 

than the other, given the extremely 

similar nature of the symbols, the 

agency believes either symbol will 

provide sufficient identification for 

ease-of-access for consumers. 

d. Tether Anchorage Marking Comments 

and Agency Responses 

1. Whether the Tether Anchorage and 

Tether Anchorage Cover Marking 

Location Is Too Restrictive 

The Alliance, MEMA, and Global 

expressed several concerns regarding 

the NPRM’s proposed requirements on 

the tether anchorage and tether 

anchorage cover marking location. The 

Alliance did not support the proposed 

requirement to locate the tether 

anchorage symbol a distance no farther 

than 25 mm from the center of the 

anchorage for uncovered anchorages. 

The Alliance stated that NHTSA 

provided no explanation for the basis of 

selecting 25 mm for tether anchorage 

labeling. The Alliance further stated that 

markings for tether anchorages in 

current vehicles can be located much 

farther away at either 50–100 mm above 

or 25–100 mm in front of the anchorage 

bars while still being easily 

recognizable.121 The Alliance pointed 

out that some current vehicles that have 

easily recognizable anchorage markings 

would not meet the proposed marking 

requirements. 

The Alliance explained that for these 

vehicles the distance from the 

anchorage bar to the edge of the recess 

well is 35 mm, and the distance to the 

symbol is 38 mm. As such, to meet the 

maximum proposed 25 mm distance, 

the clearance provided by the plastic 

bezel would need to be shortened by 13 

to 22 mm, making it more difficult for 

consumers to attach and detach the 

tether hook. The Alliance stated that 

this requirement would reduce ease-ofuse, producing the exact opposite effect 

that the NPRM is attempting to 

accomplish. 

The Alliance also requested 

clarification on how ring style tether 

anchorages 122 would be handled under 

the proposed requirements. The 

Alliance stated that type of anchorage is 

well marked, but where the tether hook 

attaches to the anchorage is 38 mm from 

the symbol. The Alliance added that to 

meet the 25 mm requirement, the size of 

the ring would need to be decreased to 

25 mm and that such a modification is 

unnecessary and would make the 

anchorage less easy to use. 

Similarly, MEMA stated that the 25 

mm distance is too constrained for 

current standard production 

components. MEMA explained that, 

depending on the functional design size 


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Figure 8. NPRM Regulatory Text Figures 25 (left) and 16 (right): ISO Tether Symbols 
1322 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

123 June 2, 2000, NHTSA–1999–6160–0022 (p3– 

5), August 11, 2003, NHTSA–2003–15438–0005 

(p3–4), and March 24, 2004, NHTSA–2003–15438– 

0011 (p2 and attachments C and D). 

124As illustrated in figure 19 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

of the component piece that surrounds 

the tether bar, such a tolerance could 

place the mark either on the edges or in 

the interior of the bar and its 

surrounding component. MEMA added 

that not only is it difficult to achieve 

such a marking (under typical molding 

and manufacturing processes), but that 

it could also potentially obscure the 

marking and impact visibility, thus 

defeating the agency’s goal to improve 

conspicuity. Further, MEMA 

commented that the proposed 25 mm 

dimension tolerance may force redesign 

of tether hook components, which could 

impact the surrounding opening of the 

tether bar, thus making attachment of 

the tether hook more difficult. MEMA 

explained that under that scenario, 

NHTSA’s goal to improve usability 

would be defeated; therefore, to 

properly mark the component 

containing the tether bar/hook 

attachment without forcing redesign of 

the component fascia or function, 

MEMA urged NHTSA to increase the 

compliance marking zone dimension to 

at least 50 mm. 

The Alliance stated that the proposed 

requirement to have the center of the 

symbol aligned with the center of the 

anchorage length to a tolerance of ±5 

mm is unnecessarily restrictive. The 

Alliance explained that a 5 mm 

tolerance from the centerline is either 

not practicable, given current seat 

labeling and construction 

manufacturing processes, or 

unnecessary to achieve the agency’s 

stated goal. In making these statements 

the Alliance referenced its comments 

and petitions for reconsideration to the 

original CRAS rulemaking, documenting 

practicability limitations.123 The 

Alliance recommended that the 

tolerance for tether anchorage markings 

be ±25 mm, consistent with the 

requirements for lower anchorage 

markings. 

The Alliance also commented that for 

some designs it is very difficult or 

impossible to include a tether anchorage 

marking that complies with the 

proposed requirements in section 

9.5.2.124 The Alliance explained that 

some tether anchorages have recessed 

plastics from which the anchorage 

protrudes and that although the mark 

does not fall within 25 mm of the center 

of the anchorages, those tether 

anchorages’ marks are clear and visible 

to the consumer. The Alliance suggested 

that tether anchorage marking locations 

be allowed in both the longitudinal and 

lateral directions from the anchorage. 

Similarly, Global explained that in some 

cases there may be no practical location 

meeting the centerline and 25 mm 

anchorage bar-pictogram distance 

criteria. Global urged the agency to 

establish less stringent criteria to allow 

for variations in vehicle interior 

architecture. Global also explained that 

the more detailed specification could be 

impractical for some vehicle designs, 

and stated that manufacturers have 

every incentive to ensure that the 

pictogram is located in a manner that is 

not confusing to consumers. 

Agency Response 

Regarding the location of the tether 

anchorages markings, we agree that the 

proposed distance from the anchorages 

to the symbol is too restrictive and that 

in some cases it could make the tether 

anchorage shorter while also making it 

more difficult to use. NHTSA also 

acknowledges comments presenting 

examples of markings that were more 

than 25 mm away from the anchorage 

while still clearly identifying the tether 

anchorage as such. In response to these 

comments, NHTSA agrees that a 

distance of 100 mm is reasonable; 

however, the agency will also require 

that no other anchorage (cargo tie down 

or similar) or structure that could be 

confused with an anchorage be closer to 

the tether anchorage marking than the 

corresponding tether anchorage (figure 

9). This requirement will ensure that the 

markings clearly identify the 

corresponding tether anchorages, while 

giving manufacturers more flexibility to 

position the markings. NHTSA believes 

that 100 mm is a reasonable distance, as 

it is still within the current lower 

anchorage location marking distance 

range. 

Further, NHTSA acknowledges 

comments made by the Alliance and 

MEMA relating to the restrictive 

tolerances proposed for the centering of 

tether anchorage markings with a ±5 

mm tolerance; however, we disagree 

with the suggestion of a ±25 mm 

tolerance. Unlike lower anchorages, 

tether anchorages do not have a required 

minimum length of 25 mm. Therefore, 

as some tether anchorages can be quite 

narrow in design, a ±25 mm tolerance 

would allow a marking located 

completely to the side of the tether 

anchorage, which may cause confusion. 


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Figure 9. Revised Distance of Tether Anchorage Marking from Tether Anchorage. 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1323 

This final rule will instead have the 

tether anchorage marking centerline 

intersect the tether anchorage along the 

tether anchorage’s length (figure 10). 

This requirement will ensure that the 

tether anchorage marking centerline 

crosses the length of the tether 

anchorage. It will also give the 

manufacturer the flexibility to choose an 

anchorage width and a tether symbol 

size that suits their manufacturing 

needs. 

The agency also agrees with the 

Alliance that in some cases it would be 

difficult to align the tether anchorage 

marking to the width of the tether 

anchorage. However, NHTSA would 

like to keep some consistency on the 

location of the markings to easily guide 

the consumer to the tether anchorage. 

Therefore, NHTSA will also allow 

locating the tether anchorage marking to 

the sides of the anchorage. Per this final 

rule’s requirements, half of the height of 

the marking must overlap/intersect the 

tether anchorage, as shown below in 

figure 11. Manufacturers may choose a 

larger symbol size (with a minimum 

height of 20 mm) that gives them the 

flexibility to meet this requirement. 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.035</GPH> ER07JA25.036</GPH>

Tether Symbol Tether Symbol Tether Symbol 

Center Line CenterUne Center Line 

I I I 

I I I 

~ J,~ J,~ I I I 

I I I 

I I I 

I I I 

I I I 

I I I 

I I I rl/2--: I I 

~ I 

Tether 

I--

I I 

Anchorage 

L --I 

Tether Anchorage Tether Anchorage 

~ 

Pass Pass Fail 

Figure 10. Tether Symbol Centered to Tether Anchorage (vertically) 

Tether Symbol 

f ·~•• Center~ 

H ._f .&, ~ ~;--&--------3- ~ Tether Anchorage 

Tether Anchorage 

Tether Anchorage 

ClessThan 

H/2 

CMoreThan 

H/2 

Pass 

Pass 

Fail 

Figure 11. Tether Anchorage Symbol Centered to Tether Anchorage (horizontally) 
1324 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

125 Klinich, Kathleen D., Manary, Miriam A., 

Malik, Laura M., Flannagan, Carol A.C. ‘‘Tether 

Anchors in Pickup Trucks: Assessing Usability, 

Labeling and performance’’. UMTRI–2016–30. 

November 2016. https://deepblue.lib.umich.edu/ 

bitstream/handle/2027.42/156027/UMTRI-2016- 

30.pdf?sequence=1&isAllowed=y. 

Finally, the agency agrees with 

comments stating that the NPRM’s 

proposed alignment and tolerances of 

the marking on the tether anchorage 

cover would create an unnecessarily 

restrictive and impractical requirement, 

as consumers will still understand that 

what is under the cover is a tether 

anchorage even without these rigid 

requirements. Such manufacturing 

precision would thus be an unnecessary 

and increased burden on manufacturers. 

As such, this final rule will still require 

the proposed marking on the tether 

anchorage cover but will not specify the 

alignment and tolerances of the marking 

location. 

3. Tether Anchorage Markings in Cargo 

Covers 

As discussed earlier in this final rule, 

NHTSA will allow the presence of cargo 

covers as long as they do not need any 

tools for removal. In addition to the 

markings by the tether anchorages, cargo 

covers will have to be marked with a 

tether symbol for each tether anchorage 

available below the cargo cover. 

There will be no requirements on the 

location of the marking on the cargo 

cover, as the location of the cargo cover 

with respect to the anchorage is varied. 

Manufacturers should indicate in their 

instruction manuals how to access the 

tether anchorages. Tether anchorages 

under the cargo cover will also need to 

be marked with the ISO symbols 

adopted in this standard. 

2. Tether Anchorage Markings for 

Routing Devices 

Global suggested that FMVSS No. 225 

should require a separate label for tether 

routing devices to assist consumers in 

proper routing of the tether strap. Global 

further suggested that a different symbol 

than the proposed tether anchorage 

symbol should be used for tether routing 

devices to avoid consumer confusion. 

The Alliance stated that given the 

proposed requirements for rigid 

anchorages in pickups for use in 

conjunction with routers, it is unclear 

whether the marking requirements can 

be met. The Alliance stated that the 

location of the marking may not be 

visible or help consumers readily 

identify and locate the correct tether 

anchorage for the corresponding seating 

position. Similarly, Global suggested a 

separate label for tether routing devices 

and/or use of a different tether symbol 

to avoid consumer confusion. 

Agency Response 

NHTSA disagrees with comments 

suggesting that FMVSS No. 225 should 

require a separate label for tether 

routing devices to assist consumers in 

proper routing of the tether strap and 

disagrees that a different symbol than 

the proposed tether anchorage symbol 

should be used to avoid consumer 

confusion. Specifically, we disagree that 

there is a need to provide a different 

label and symbol for pickup trucks, as 

part of the effort of this rulemaking is to 

standardize markings and features to 

help develop simple educational efforts. 

NHTSA has reached this decision after 

careful consideration of comments 

received and the findings of a UMTRI 

research study,125 which showed that 

using different labeling strategies to 

identify and guide users to the tether 

anchorages had no effect on tether use, 

attaching the tether to the correct 

anchorage, or correct tether use. NHTSA 

does recognize the unique aspects of 

pickup trucks, and believes that 

standardizing tether markings, paired 

with instructions in user manuals and 

education outreach efforts, will help 

improve current levels of correct tether 

use. 

In response to concerns regarding 

difficulty meeting the proposed marking 

requirements for rigid anchorages in 

pickup trucks in conjunction with 

routers in pickup trucks, as discussed 

previously, this final rule allows for the 

use of flexible tether anchorages that 

may also be used as routers. 

NHTSA also recognizes that tether 

anchorages in pickup trucks may not be 

visible unless the consumer looks for 

them behind the head restraint. 

Notwithstanding this issue, the agency 

believes the tether markings required by 

this final rule are warranted both for 

standardization purposes and consumer 

awareness. However, given the 

expressed concerns over the unique 

designs of some pickup trucks, if a 

marking cannot be positioned within 

the allowed distances of this final rule, 

NHTSA will permit its placement on the 

flexible routing/tether anchorage device 

with a tag, or for the marking to be 

positioned within 100 mm of the 

anchorage. 

4. Differences in the NPRM’s Tether 

Symbol in Tether Anchorage Marking 

Location (No Cover and With Cover) 

Figures and the ISO Symbol 

MEMA and the Alliance stated that 

figures 26 and 27 referenced in the 

proposed regulatory text (figure 12) 

depict a different pictogram than the 

proposed ISO Tether Symbol inside a 

label and that the pictogram is not 

referenced elsewhere. MEMA requested 

clarification on this issue and asked that 

NHTSA use consistent pictograms in all 

of its figures in the regulation. 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.037</GPH>

1'.l!ltfUD 111211.Di!i 

.......... 

Figure 12. NPRM Figures 26 (left and center) and 27 (right): Tether Anchorage Marking 

Locations with No Cover and Cover Respectively. 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1325 

126 It is the agency’s understanding that Dr. Baer 

is referencing the 32-inch head excursion limit 

allowed in FMVSS No. 213 when CRSs are tested 

without a tether attached. 

127See figure 25 of Alliance Comments Link: 

www.regulations.gov/comment/NHTSA-2014-0123- 

0027. 

128An earlier section of this final rule discusses 

how, contrary to the NPRM’s proposal, NHTSA will 

still allow flexible tether anchorages and routers as 

a solution for pickups, single row vehicles and 

buses. 

Agency Response 

The agency is making changes to the 

pictograms so that they match the ISO 

standardized markings to avoid any 

confusion. 

VIII. Applying FMVSS No. 225 to 

Vehicles Currently Excluded From 

FMVSS No. 225 

The 2015 NPRM requested comments 

on the feasibility of installing tether 

anchorages in convertibles, as FMVSS 

No. 225 currently excludes convertibles 

from having to provide tether 

anchorages in rear seating positions (see 

S5(a) of FMVSS No. 225). The NPRM 

proposed deleting the tether anchorage 

exclusion for convertible vehicles 

because several convertible model 

vehicles have demonstrated that they 

can accommodate them. Specifically, 

the agency found that among 35 

convertible vehicle models from the 

2013 vehicle fleet, 10 were equipped 

with the full CRAS (lower anchorages 

and tether anchorage) in two rear DSPs, 

14 were equipped with only the lower 

anchorages at two rear DSPs, and 11 

were not equipped with any anchorages. 

NHTSA also requested comment on 

whether the exclusion of lower 

anchorages in rear designated seating 

positions where interference with the 

transmission and/or suspension 

components prevent the location of the 

CRAS lower anchorages anywhere 

within specified zones (S5(e) of FMVSS 

No. 225) is still needed. NHTSA 

explained that manufacturers have 

gained experience in designing and 

installing vehicle seats with lower 

anchorages since the issuance of FMVSS 

No. 225. The 2015 NPRM tentatively 

determined there is no longer a need for 

S5(e) and proposed deleting it. NHTSA 

requested comment on why the 

technical problems that existed at the 

time of the implementation of the final 

rule in 1997 could not be overcome by 

the knowledge gained since 1997 and on 

the feasibility of installing tether 

anchorages in the second row of 

convertibles, and in the first row in 

convertibles that do not have a second 

row. 

Comments 

Several commenters supported 

removing the exclusion of CRASs on 

convertibles, with some pointing out 

that manufacturers have had many years 

of experience installing CRASs in 

vehicles and should now have the 

experience to overcome obstacles in 

installing tether anchorages in these 

vehicles. UMTRI stated that the 

challenge of implementing tether 

hardware in pickup trucks is no greater 

than what would be required for 

convertible vehicles, and that the 

innovations and designs that have been 

developed to allow tether anchorages in 

pickup trucks should be sufficient to 

guide methods to implement tether 

hardware in convertibles. 

Dr. Baer commented that if the 

exemption for convertible vehicles does 

continue, convertibles should be 

required to state that forward-facing 

children may not ride in the positions 

lacking tether anchorages. Dr. Baer 

further stated that the tether anchorage 

is of greater importance in vehicles with 

minimal head excursion room, as most 

convertibles have far less than the 32 

inches in their back seats.126 Dr. Baer 

stated that exempting these vehicles 

leaves children at risk, as parents 

continue to put forward-facing children 

in these back seats, and that because 

most rear-facing CRSs cannot fit in a 

convertible, children placed in car seats 

in the back are most likely in a forwardfacing seat. Advocates stated that the 

elimination of this exemption will serve 

as an important incentive to meet 

current safety standards for 

manufacturers that do not offer rear 

tether anchorages in convertibles. 

The Alliance and Porsche supported 

continued exemption for convertibles. 

The Alliance explained that some 

vehicle manufacturers may have 

addressed certain technical problems 

(such as deployable head restraints) by 

placing the tether anchorages on the 

vehicle seatback or the vehicle structure 

behind the passenger seat.127 However, 

the Alliance pointed out that the 

proposed FMVSS No. 225 S6.1(b) will 

no longer allow for this type of solution, 

because the vehicle seatback would 

have to be unlatched and moved 

forward to access the top tethers. 

Therefore, the Alliance recommended 

continued exemption for convertible 

vehicles from the installation 

requirements for tether anchorages. 

The Alliance and Porsche also 

opposed removing S5(e) from FMVSS 

No. 225 on the grounds that the same 

issues that existed when S5(e) was 

created may exist today or in the future; 

specifically, space limitations or 

transmission/suspension part 

interference issues may prevent lower 

anchorages from being located in the 

zone described by S9.2 or S15.1.2.2(b) 

so that the attitude angles of S15.1.2.2(a) 

cannot be met. The Alliance and 

Porsche also stated that S5(e) should be 

retained to maintain harmonization 

with ECE Regulation 14. 

Agency Response 

After careful consideration of 

comments received, this final rule will 

remove the exception provided for 

convertibles in S5(a) for the lower 

anchorages. NHTSA disagrees with 

commenters suggesting that the NPRM’s 

proposed prohibition on moving the 

vehicle seat to reach the tether 

anchorages would make it impossible 

for some convertibles to have a tether 

anchorage. Specifically, convertible 

vehicles could incorporate a tether 

router/anchorage to accommodate this 

requirement through a method similar 

to that used by pickup trucks,128 which, 

like many of these currently excluded 

vehicles, have a back wall instead of a 

package shelf or trunk space that would 

give more options for installing the 

tether anchorages. Further, in response 

to comments that the lower anchorage 

exception in (S5(e)) should not be 

removed because the same challenges 

that existed at the time of 

implementation still exist today, 

NHTSA has observed that some of these 

vehicles have already been redesigned 

to accommodate anchorages despite 

existing challenges. For example, the 

Porsche 911 Carrera already includes 

the implementation of the lower 

anchorages in newer designs. While the 

agency acknowledges that changes 

might be required for some vehicles to 

accommodate the lower anchorages, 

industry has already shown that it is 

possible to do it in ways that would 

comply with this final rule. 

However, taking into consideration 

comments received and in 

acknowledgement that changes required 

to meet this final rule may include 

redesign of convertibles and/or vehicles 

with a rear designated seating position 

for which interference with 

transmission and/or suspension 

components prevents the location of the 

lower bars of the child restraint 

anchorage system in the allowable 

zones, this final rule will provide a 6- 

year lead to provide manufacturers 

enough time to accommodate any 

necessary changes. 


ddrumheller on DSK120RN23PROD with RULES3
1326 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

129 Kallan MJ, Durbin DR, Arbogast KB. ‘‘Seating 

patterns and corresponding risk of injury among 0- 

to 3-year-old children in child safety seats’’ 

Pediatrics. 2008 May;121(5):e1342–7. doi: 10.1542/ 

peds.2007–1512. PMID: 18450877. 

130CR relayed that only two manufacturers 

consistently allow use of the inboard anchorages for 

center lower anchorage installation in their owner’s 

manuals, if the practice is also allowed by the CRS 

manufacturer. 

IX. Public Responses to Request for 

Comments and NHTSA’s Views 

a. Center Rear Seat—Dedicated, Shared, 

or No Lower Anchorages 

Currently FMVSS No. 225 (S4.4) 

requires vehicles with three or more 

forward-facing rear DSPs to have a 

CRAS at no fewer than two of the rear 

DSPs. Vehicles with three or more 

forward-facing rear DSPs must currently 

have a tether anchorage at a third 

forward-facing DSP. At least one tether 

anchorage must be in a forward-facing 

rear DSP other than an outboard DSP 

(i.e., a center seat). The March 5, 1999, 

final rule (64 FR 10803) acknowledged 

that vehicle manufacturers would likely 

install the lower anchorages in the two 

outboard seating positions as two CRAS 

were unlikely to fit side-by-side in the 

rear seat. Thus, the requirement for a 

third tether anchorage at a center seat 

provides consumers the option to install 

child restraints in a center DSP, where 

there is the vehicle’s belt system and a 

tether anchorage. Vehicle surveys of 

applicable MY 2010–2011conducted by 

NHTSA and UMTRI revealed that of 

vehicles with a rear center DSP, none 

offered two dedicated lower anchorages 

in the center position. 

Since the issuance of the 1999 final 

rule, many consumers have expressed a 

desire to use the rear center seating 

location to install a CRS using the lower 

anchorages. In response to these 

requests, NHTSA’s 2015 NPRM sought 

comment on possible ways to address 

this issue, suggesting and seeking 

comment on the following approaches: 

(1) Require a set of lower anchorages 

in the rear center seating position, 

instead of one or both of the CRASs 

available at the outboard positions in 

most current vehicle models. We 

requested comment on the feasibility of 

installing a CRAS in a rear center 

seating position and on whether we 

should require such installation. 

(2) Require a third set of dedicated 

lower anchorages in the rear center seat. 

The agency requested comment on the 

feasibility of installing a dedicated 

CRAS in the rear center seating position 

in addition to the two-anchorage system 

in the outboard seating positions in 

vehicles with 710 mm (27.9 in) or more 

distance between the centerlines of 

outboard lower anchorages. 

(3) Require a simulated CRAS. We 

requested comment on whether the 

standard should require a simulated 

CRAS in the rear center seating position 

consisting of the inboard lower 

anchorages of the CRAS in the two 

outboard seating positions and the 

center seat tether anchorage. 

Comments 

Dedicated, Shared, or No Lower 

Anchorages in Center Seat 

IIHS, SRN and Global supported the 

ability to use center lower anchorages 

(simulated or dedicated) but indicated 

that the decision to provide dedicated 

anchorages or to allow simulated ones 

should be left up to the vehicle 

manufacturer. IIHS and SRN explained 

that vehicle manufacturers are in the 

best position to determine the solution 

that works best in each vehicle, and that 

requiring dedicated anchorages in all 

three second-row seats, where available, 

may increase confusion and the 

likelihood for misuse if lower anchorage 

sets overlap and it is not clear which 

anchorage pairs are intended for each 

seat position. SRN also suggested that 

CRS manufacturers should be required 

to address simulated CRASs in their 

instruction manuals and be encouraged 

to test for this usage so that it can be 

permitted, whenever possible, with 

their CRSs that have flexible lower 

anchorage straps. 

Similarly, Global stated that the 

decision on how to provide center lower 

anchorages should be left to the 

manufacturer to avoid limiting design 

flexibility and interior layout. Global 

commented that for smaller sized 

vehicles with two rows, the current 

CRAS requirements are adequate for 

rear seating positions. Global added that 

if anchorages for a rear center seating 

position were required it would not 

allow a rear seat fold-down design that 

splits at the middle (50 percent 

centerline), as there would be 

interference with an installed rear 

center CRS. 

SRN stated that parents concerned 

with safety often wish to put their child 

in the center seating position. SRN 

further stated that many sources 

indicate that the center seating position 

is the safer location (including 

American Academy of Pediatrics (AAP) 

and many CRS manufacturer websites), 

supported by at least one major study 

showing it to be 43 percent safer than 

an outboard position.129 SRN indicated 

support for the options to use lower 

anchorages in the center, as it is 

something many caregivers want. SRN 

explained that many caregivers install 

the CRS in the center seat using what 

NHTSA calls a simulated system, but in 

circumstances in which doing so is not 

allowed by one or both manufacturers 

(CRS and vehicle). SRN added that since 

the majority of caregivers do not get 

assistance from a CPST, they are often 

surprised when told they may not do 

use a simulated system because the 

installation would otherwise appear to 

be correct (sufficiently tight). SRN 

further stated that some caregivers are 

upset when they realize they cannot use 

the lower anchorages in the preferred 

center position, especially when it is 

their impression that an installation is 

safer when using the lower anchorages, 

so they feel they are in a no-win 

situation. Finally, SRN stated that the 

seat belt in the center is not always easy 

to use for installing a CRS and does not 

always provide an adequately tight 

installation. 

UMTRI, CR, and Advocates supported 

the addition of a dedicated third set of 

lower anchorages to the center position 

of rear seats when there is space 

available, and a simulated lower 

anchorages installation allowance for 

vehicles with insufficient space to fit a 

dedicated set of lower anchorages. CR 

supported increased education from 

manufacturers to allow a simulated 

lower anchorage installation for flexible 

lower anchorage straps on wider lower 

anchorages.130 CR added that 

standardized spacing is still necessary 

for the smaller population of CRSs 

equipped with rigid attachments but 

stated that the recommendation to use 

simulated/non-standard spacing would 

help installation success for the larger 

number of seats equipped with flexible 

lower anchorage straps. 

UMTRI stated that the frequency of 

having three children in a single row 

using CRS is low; however, having 

center and outboard seating positions 

equipped with (or allowed to use) lower 

anchorages provides flexibility and 

options, so parents traveling with one 

child can use the safest center position, 

but can use both outboard positions if 

CRSs are too large to be installed in 

adjacent seating positions. 

UMTRI suggested that testing on 

nonstandard spacing of lower 

anchorages using CRSs with both pushon and hook-on connectors be 

conducted. UMTRI explained that since 

the majority of tests run to evaluate the 

effects of non-standard spacing have 

been run with hook-on connectors, a 

more diverse data set might reassure 

CRS manufacturers that non-standard 

spacing is acceptable across a variety of 

products. 

Advocates indicated that they have 

been a proponent of equipping the rear 


ddrumheller on DSK120RN23PROD with RULES3
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1327 

131 Klinich, K.D., Manary, M.A., Orton, N.R. 

‘‘Feasibility of Center LATCH.’’ NHTSA–2014– 

0123–0007. 

132As illustrated in figure 20 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Continued 

center seating position with lower 

anchorages for many years since the 

CRAS was proposed in 1997. Advocates 

added that they also urged NHTSA to 

require full CRS anchorage systems in 

all center seats during the 2007 public 

meeting. Advocates explained that 

current (FMVSS No. 225) requirements 

have generally resulted in consumers 

installing CRSs with the CRAS in the 

outboard seating positions when the 

center rear seating positions did not 

have the lower anchorages available, but 

that many consumers have expressed a 

desire to place a CRS in the rear center 

seat. 

Advocates stated that many other 

child passenger safety authorities have 

also long recommended that when a 

child is transported the safest location is 

the center rear seating position. 

Advocates explained that placing the 

child in the rear seat moves the child 

away from safety concerns associated 

with travel in the front passenger seat 

and that locating the CRS in the rear 

center position keeps children away 

from doors and windows and potential 

intrusion in the event of a side impact 

crash. For this reason, Advocates stated 

that NHTSA’s not addressing the need 

for a CRAS in the center rear seat in the 

initial 1999 final rule, and in the 

intervening 15 years, has been difficult 

to understand. 

Advocates added that a 2009–2010 

survey conducted by Safe Kids revealed 

approximately a third of children 

restrained by a CRS ride in the rear 

center seat. Advocates stated the desire 

to seat young children in CRSs in the 

rear center seating position should not 

be new information to the NHTSA, as 

the agency itself, along with many 

passenger and vehicle safety 

organizations, had been recommending 

the use of the rear center seating 

position as the optimal location from a 

safety standpoint for a single CRS for 

many years, even before concerns about 

airbag interactions with young children 

seated in the front passenger seating 

position became known. Advocates also 

referenced a December 2014 study 

performed for NHTSA by UMTRI that 

found that the majority (56 percent) of 

2010–2011 MY vehicles included in the 

survey could support a dedicated set of 

lower anchorages in the rear center 

seat.131

Ford stated that the UMTRI 

conclusion that seats with 710 mm (27.9 

inch) or more distance between the 

centerlines of outboard lower 

anchorages would have sufficient space 

to provide three sets of usable dedicated 

lower anchorages in the right, center, 

and left seating positions in the rear row 

does not consider spacing issues related 

to seatbacks that fold down. Ford stated 

it has found a high customer 

expectation for folding seatbacks due to 

the cargo carrying flexibility they offer, 

and now offers this feature on nearly all 

its passenger cars and SUVs. Ford 

commented that some parents want to 

place children in the center position 

using child restraint anchorages and 

that it has evaluated different 

alternatives to address consumers’ 

desires. Ford stated that large vehicles 

may be able to provide an additional 

pair of lower anchorages in the center 

position; however, this option is not 

feasible on most seats due to packaging 

of seat belt hardware and seatback pivot 

mechanisms. 

Ford agreed with NHTSA’s 

conclusion that use of lower anchorages 

spaced wider than 280 mm is acceptable 

in most vehicles, provided the child 

restraint can be installed securely, and 

the child restraint manufacturer permits 

this installation. Ford stated that it has 

found loads applied to lower simulated 

anchorages spaced 520 mm apart are 

comparable to loading of anchorages 

spaced 280 mm apart. Since the 

anchorages are already tested using the 

SFAD2, Ford expressed its belief that 

additional testing would be redundant. 

Ford stated that in recognition that some 

seat designs may preclude secure 

installation, it has included the 

following owner manual notices, which 

provide clear direction to a care giver 

using lower anchorages at the center 

seating position.: 

• Depending on where you secure a 

child restraint, and depending on the 

child restraint design, you may block 

access to certain safety belt buckle 

assemblies and LATCH lower anchors, 

rendering those features potentially 

unusable. To avoid risk of injury, 

occupants should only use seating 

positions where they are able to be 

properly restrained. 

• Never attach two child safety seats 

to the same anchor. In a crash, one 

anchorage may not be strong enough to 

hold two child safety seat attachments 

and may break, causing serious injury or 

death. 

• The standardized spacing for 

LATCH lower anchors is 11 inches (28 

centimeters) center-to-center. Do not use 

LATCH lower anchors for the center 

seating position unless the child seat 

manufacturer’s instructions permit and 

specify using anchors spaced at least as 

far apart as those in this vehicle. 

• The lower anchors at the center of 

the second-row bench seat are spaced 

520 mm (20.5 inches) apart. The 

standardized spacing for LATCH lower 

anchors is 280 mm (11 inches) centerto-center. A child seat with rigid 

LATCH attachments cannot be installed 

at the center seating position. LATCH 

compatible child seats (with 

attachments on belt webbing) can only 

be used at this seating position provided 

that the child seat manufacturer’s 

instructions permit use with the anchor 

spacing stated. Do not attach a child seat 

to any lower anchor in an adjacent child 

seat that is attached to that anchor. 

Manufacturer’s Option To Provide 

Dedicated Lower Anchorages, and To 

Recommend or Not Recommend 

Sharing Lower Anchorages 

The Alliance explained that 

manufacturers need to balance the 

necessity for CRS anchorages with other 

customer requirements like seat 

adjustments, the location of seat belts, 

etc., and that often vehicle packaging 

precludes providing a dedicated set of 

center lower anchorages. The Alliance 

added that many vehicles (e.g., small 

cars and vehicles where the rear seat is 

between the wheel wells) are not wide 

enough to accommodate three distinct 

CRAS-equipped positions. The Alliance 

stated that even where the rear seat is 

wide enough, the vehicle may have 

insufficient structure to carry the 

simultaneous loading of three sets of 

anchorages. 

The Alliance further commented that 

in certain vehicles, components such as 

a seatback adjuster would not provide 

the space required for a dedicated third 

set of lower anchorages. The Alliance 

added that vehicles using a separate 

fore/aft seat movement in a split rear 

seat may not be able to accommodate 

two pairs of lower anchorages on an 

individual section of the seat. 

The Alliance explained that vehicle 

manufacturers have, for various reasons, 

equipped certain vehicles with the 

potential to attach a child seat in the 

rear center seating position while not 

providing three distinct sets of child 

restraint lower anchorages in the rear. 

As an example, the Alliance pointed to 

a vehicle configuration using a 60–40 

split rear seat with greater than 710 mm 

between the centerlines of the outboard 

lower anchorages. Instead of a third set 

of lower anchorages, the vehicle is 

equipped with a ‘‘fifth’’ lower anchorage 

provided to create a set of center 

anchorages by ‘‘borrowing’’ from the 

inboard anchorage of the adjacent 

seating position.132 The Alliance stated 


ddrumheller on DSK120RN23PROD with RULES3
1328 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

133As defined and shown in FMVSS No. 225, 

figure 2. 

134As illustrated in figure 21 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

135As illustrated in figure 22 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link:www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

136As illustrated on page 28 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

Link: www.regulations.gov/comment/NHTSA-2014- 

0123-0027. 

137As illustrated in figure 23 of the Alliance 

comments in Docket No. NHTSA–2014–0123–0027. 

In this example the Alliance showed that while 

there is good access to the seat belt buckle for the 

adjacent seating position, interference with the CRS 

lower anchorage strap could adversely affect the 

positioning of the lap belt on an adjacent occupant 

(in this case it would cause the lap belt to be 

positioned high on a small occupant, increasing the 

potential for submarining). Link: 

www.regulations.gov/comment/NHTSA-2014-0123– 

0027. 

138Alliance provided an example of an owner’s 

manual warning in its comments (page 30) in 

Docket No. NHTSA–2014–0123–0027. Link: 

www.regulations.gov/comment/NHTSA-2014-0123- 

0027. 

139 Kallan, M.J., Durbin, D.R., and Arbogast, K.B. 

‘‘Seating Patterns and Corresponding Risk of Injury 

Among 0- to 3-Year-Old Children in Child Safety 

Seats’’ Pediatrics 2008 and Mayrose, J.S. and Priya, 

A. ‘‘The safest seat: effect of seating position on 

occupant mortality’’ J Safety Res. 2008. 

that this arrangement allows for the 

potential to attach either a center child 

restraint or an outboard child restraint 

(on the 60 percent seat side). The 

Alliance added that other solutions to 

provide center anchorages in small 

vehicles have led to customer 

confusion, such as where anchorage 

locations overlap, causing customer 

confusion as to which anchorages 

created a ‘‘pair’’ to install a child 

restraint equipped with flexible 

attachments. 

The Alliance explained that the space 

required by a child restraint system and 

the location and accessibility of the 

lower anchorages are regulated by using 

a Child Restraint Fixture (CRF),133 and 

that the dimensional characteristics of a 

CRF were developed to represent a 

typical child restraint system. The 

Alliance further explained that in a 

vehicle with over 710 mm between the 

centerline of the two outboard lower 

anchorages, three CRFs (that represent a 

child restraint system) 134 are not 

feasible in the same row at the same 

time, and thus requiring manufacturers 

to design a vehicle with three sets of 

lower anchorages is not practicable 

because installing three child restraints 

simultaneously in such vehicles cannot 

be achieved in the field. The Alliance 

therefore stated that it recommends that 

NHTSA not require a dedicated set of 

center lower anchorage in addition to 

the two outboard lower anchorages. 

The Alliance next described a midsized SUV with a distance between the 

centers of outboard seating positions of 

800 mm, and the distance between the 

inboard lower anchorages of 520 mm.135

The Alliance explained that customer 

expectations for split back, reclining, 

fold flat seatbacks, center fold down 

armrest, and an expectation for a bias in 

roominess and comfort at the second 

row outboard positions would preclude 

the addition of dedicated lower 

anchorages in the center position. The 

Alliance added that a caregiver still has 

the option to use the center seat belt to 

secure a child restraint in that position. 

The Alliance stated that there are 

circumstances where it is permissible to 

install a CRS that has flexible lower 

anchorage attachments in the rear center 

location using a simulated restraint 

anchorage system. However, it 

explained that in order to do so, several 

factors need to be considered and 

controlled. Specifically, the Alliance 

listed the following considerations: 

• The center position must be a DSP 

(or else a CRS installed using the 

outboard anchorages might be very 

unstable). The Alliance explained that 

in vehicles without a center DSP, 

simulated rear center child restraint 

locations are typically not permitted by 

the vehicle manufacturer. 

• The spacing between the 

anchorages must be within a range 

acceptable to both the vehicle and CRS 

manufacturers and that for rigid 

anchorage CRSs with fixed spacing, this 

will be a significant limitation. 

• The vehicle seats must be 

positioned such that the lower 

anchorage bars on the outboard seats are 

collinear (i.e., one seat cannot be 

positioned either forward or rearward of 

the other). Alliance explained that this 

can occur if the two seating positions 

can be moved fore/aft independently.136

• The CRS manufacturer must not 

recommend against use of non-standard 

spacing for the particular CRS model. 

• There must be no more than one 

CRS attached to any lower anchorage, 

and, 

• There must be no contact or 

obstruction between the CRS lower 

anchorage straps and vehicle safety belts 

being used in the outboard positions 

(such contact could damage the straps 

and/or the belts and could adversely 

affect initial belt routing and/or safety 

performance in a crash).137

The Alliance stated it would be 

difficult to effectively communicate 

these limitations to the majority of 

consumers. The Alliance added that 

some manufacturers allow the use of 

‘‘simulated’’ center anchorage positions 

in specific vehicles that meet the above 

conditions but that the majority of 

vehicle/seat configurations may not 

safely accommodate such fitment. As a 

result, the Alliance explained that 

vehicle manufacturers provide vehiclespecific guidance to consumers about 

when it is appropriate to use the 

simulated center anchorage position as 

well as instructions for using the 

simulated center anchorage position. 

The Alliance further stated that the 

LATCH Manual (published by Safe Ride 

News) also documents the vehicles that 

provide this option; however, since 

such fitment cannot be universally 

applied to all vehicles, seating 

configurations, and CRSs, the Alliance 

does not recommend that the agency 

issue a ‘‘blanket’’ recommendation in 

this area. 

The Alliance also commented that 

there is no regulatory test device to 

assess the strength of simulated CRAS. 

The Alliance explained that neither the 

SFAD 1 nor the SFAD 2 can be used to 

test a set of lower anchorages spaced 

wider than 11 inches apart. The 

Alliance recommended that a 

standardized test fixture and test 

procedure should be developed for both 

the CRS manufacturers (to assess 

integrity and performance in frontal and 

side impacts) and for the vehicle 

manufacturers (to assess anchorage 

strength) if the agency wishes to 

encourage wider acceptance of 

simulated center anchorage systems in 

vehicles. 

The Alliance commented that another 

concern with the simulated rear center 

CRAS is that consumers may attach two 

child restraint systems to the inboard 

anchorage of an outboard seating 

position. The Alliance explained that in 

such cases, the combined loading from 

two CRSs might overload the single 

lower anchorage, causing it to fail in a 

crash. The Alliance stated that although 

manufacturers can provide warning 

statements in their owner’s manuals for 

such a scenario,138 this does not prevent 

caregivers from making this error. The 

Alliance further stated that this misuse 

scenario is why manufacturers do not 

support such simulated rear center 

anchorage systems. 

Dr. Baer added that studies of both 

adults and children show that the center 

is the safest spot in the back seat,139 and 

as such, the focus should be put on 

requiring vehicle manufacturers to 

design their center seats in ways that 

accommodate a car seat. Dr. Baer further 

stated that the proposed requirement for 

the installation of center lower 

anchorages in vehicles with 710 mm or 


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140The 710 mm rear seat width limit was 

determined by UMTRI ‘s NHTSA-sponsored study. 141 Klinich, K.D., Manary, M.A., Orton, N.R. 

‘‘Feasibility of Center LATCH.’’ NHTSA–2014– 

0123–0007. 

more space between the centerlines of 

the outboard lower anchorages is an 

important step to increasing the number 

of vehicles on the road that can more 

easily accommodate CRSs in a wider 

variety of configurations and 

installation methods. 

Center Seat Use of Simulated Lower 

Anchorages Only When CRS and 

Vehicle Allow It 

Graco encouraged the CRS and 

vehicle manufacturers to include 

statements on whether they endorse the 

use of simulated CRAS in rear center 

seating positions in instruction 

manuals. However, Graco did not 

support a requirement on the use of 

simulated center seat anchorages, as 

some vehicles may have split center 

seating that would cause the possibility 

of misuse by the consumer. Graco 

further explained that CRS connector 

designs may be limited in their 

tolerance for attachment to the vehicle 

anchorages. As such, Graco explained 

that it recommends an instruction 

manual recommendation for simulated 

center seat anchorage use only when 

both the vehicle and CRS manufacturers 

would allow its use. 

Dr. Baer commented that while many 

parents are creating their own simulated 

CRASs in the center of their vehicles 

(when the vehicle and CRS 

manufacturers prohibit it), she is 

concerned that the simulated CRAS as 

presented in the NPRM may increase 

injury risk for the following reasons: 

1. Dr. Baer stated that when the 

simulated position’s lower anchorages 

are wider than 11 inches, the lower 

anchorage hardware typically crosses 

over the seat belt buckle for both side 

seats—meaning that an adult trying to 

ride in back will not be able to wear a 

seat belt, which is clearly a dangerous 

situation not only for the adult, but 

everyone else in the vehicle as well. 

2. Dr. Baer stated that when the 

simulated position has one lower 

anchorage that is shared with one of the 

side seats, several issues arise, including 

that the shared lower anchorage 

typically blocks the seat belt buckle for 

the side seat, or caregivers may try and 

attach two car seats to one lower 

anchorage. 

3. Dr. Baer commented that simulated 

positions may have interference with 

the usage of the side seat belt buckles. 

She further commented that the 

interference is less in vehicles that offer 

side seat belt buckles that are on a 

flexible webbing stalk, instead of those 

that are on rigid stalks and/or are flush 

mounted with the vehicle seat cushion. 

However, Dr. Baer stated that all 

vehicles should allow simulated lower 

anchorages, as there are cases where a 

caregiver does not have adults riding in 

back, and/or the lower anchorage strap 

does not interfere with adjacent seat belt 

hardware. 

4. Dr. Baer stated not all CRs in the 

United States allow for an installation 

with lower anchorages spaced wider 

than 11 inches, which might cause more 

confusion over where and when a lower 

anchorage installation is permitted. 

Agency Response 

After careful review of comments 

received, NHTSA has decided not to 

include any new requirements on the 

center seating position if a center DSP 

is available. The agency does not believe 

that a 710 mm 140 rear width criterion 

for determining whether a dedicated 

lower anchorage should be required is 

sufficient, as other design factors 

brought up by commenters come into 

play to ensure correct use. Specifically, 

the rear seat environment is complex 

and such a requirement could limit 

vehicle manufacturer design options to 

provide features in high demand by 

consumers, such as foldable seatbacks. 

The agency is concerned that new 

requirements might have unintended 

consequences, such as vehicle 

manufacturers opting to make vehicles 

without a center DSP to accommodate 

high demand features such as foldable 

seats instead of a center DSP that can be 

used to install a CRS with seat belts. 

Additionally, the UMTRI study that 

determined the 710 mm width in rear 

seats did not account for the 

complexities of vehicle designs with 

hardware for foldable seats.141 Further, 

at this moment, the agency does not 

have an estimate of how much space is 

necessary to include such features and 

how difficult it is to accommodate both 

features (dedicated center lower 

anchorages and seat folding hardware). 

The 710 mm rear width criterion is too 

simplistic as it cannot account for a set 

of more complex designs and NHTSA 

would need further studies to develop 

requirements that would be more 

encompassing of vehicle designs that 

won’t risk the elimination of the center 

designated seating position by the 

manufacturer. 

NHTSA has also decided not to 

require vehicle manufacturers to 

recommend a simulated lower 

anchorage center seating position if a 

center DSP is available. NHTSA made 

this determination after careful review 

of concerns raised by manufacturers, 

who pointed out several issues with 

simulated lower anchorages in the 

center seating position that could 

increase misuse of the anchorages, 

including: (1) where a vehicle rear seat 

is split (50/50 or 60/40) and can be 

moved for-aft, the lower anchorages, 

being in different sections of the rear 

seat, may not be collinear; (2) the 

consumer would have to be aware that 

only one CRS can be used on a 

simulated anchorage; (3) both CRS and 

vehicle manufacturers must allow the 

use of non-standard lower anchorages 

spacing; (4) the spacing between the 

simulated center lower anchorages must 

be within a specified range that is 

acceptable to both vehicle and CRS 

manufacturers; and (5) installing a CRS 

in a simulated lower anchorage center 

position should not interfere with the 

safety belts being used in the outboard 

positions such that they could be 

damaged or produce a bad belt fit for the 

outboard occupant. 

NHTSA agrees with SRN, Ford, and 

IIHS’s suggestion that the option to 

provide a dedicated or simulated center 

lower anchorage seating position should 

be left to the vehicle manufacturer. 

NHTSA believes that vehicle 

manufacturers should determine 

whether they will provide a lower 

anchorage equipped center seating 

position (if a center DSP is available) by 

including a dedicated set of lower 

anchorages, or recommending a 

simulated one, as they can take into 

consideration all the other design 

restrictions and requirements they have. 

Manufacturers must also make the 

choice on whether there may be no 

lower anchorage in the center seating 

position. 

In summary, the agency will not 

adopt additional requirements in 

vehicles to provide means of installing 

a CRS in the center seat using simulated 

lower anchorages at this time. The 

different designs in vehicles make it 

difficult to standardize certain aspects 

of the lower anchorages and the agency 

has not fully evaluated the impact of 

some of the requirements on all the 

vehicle models. For this reason, NHTSA 

believes that the recommendation of 

using the CRAS in the center seat (if a 

dedicated one is not provided) is best 

left for the vehicle manufacturer to 

decide and establish the conditions on 

how they should be used (i.e., for/aft 

seating position on a split bench, seat 

belt interference, etc.). NHTSA 

encourages vehicle and CRS 

manufacturers to provide in their 

owner’s manuals instructions to the 

consumer on how and if simulated 

lower anchorages can be used for a 

center seating position. Consumers 


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142The agency observes that many CRSs are 

difficult to install adjacent to each other because 

they are wide and occupy part of the adjacent seat. 

should be directed to see both vehicle 

and CRS instruction manuals to decide 

whether they can use and how to use a 

non-standard lower anchorage in the 

center seat. 

Recommendation To Not Install CRSs in 

the Rear Center Seat if There Are No 

Dedicated Lower Anchorages 

Dr. Baer commented that a few 

MY2015 vehicles have two dedicated 

lower anchorages in the center position 

(for a total of 6 lower anchorages in the 

rear seat) that do not crisscross with any 

of the other lower anchorages. However, 

for these vehicles, Dr. Baer explained 

that the spacing between some of the 

lower anchorages is so close together 

(often less than 2 inches apart) that it is 

impossible to install 2 CRSs side-by-side 

in the center and side position, as CRSs 

are typically 6–10 inches wider than the 

11 inches between their lower 

anchorage connection points. 

Dr. Baer proposed that if a center 

seating position does not have lower 

anchorages, it must be assumed that the 

position was likely too narrow to 

accommodate it, and the vehicle 

manufacturer must clearly state in its 

owner’s manual that this position is too 

narrow to accommodate a car seat or 

booster. Dr. Baer also stated that the 

issues with the lack of usability of the 

center seat extend beyond the lower 

anchorages. Specifically, she asked why 

it is acceptable for vehicle 

manufacturers to sell a vehicle 

(especially one targeted to families) 

where it is impossible to secure any CRS 

to the center seat without taking up the 

adjacent seating position by virtue of the 

CRS blocking an adjacent position’s seat 

belt buckle. Dr. Baer stated that several 

vehicles cannot accommodate a car seat 

in the center without sacrificing the rear 

driver’s side seat, turning the vehicle 

into a 2-seater back seat instead of a 3- 

seater. Dr. Baer stated this is something 

that dealerships do not mention to 

families, nor do all of the manuals 

clearly explain it. 

Agency Decision 

NHTSA disagrees with Dr. Baer’s 

suggestion that if a center seating 

position does not have lower anchorages 

it must be assumed that the position 

was likely too narrow to accommodate 

it. NHTSA also disagrees with Dr. Baer’s 

suggestion that in this scenario the 

vehicle manufacture must clearly state 

in its owner’s manual that the position 

is likely too narrow to accommodate a 

car seat or booster seat. While NHTSA 

recognizes concerns that in some cases 

the center seat may be too narrow to 

accommodate some wider CRS designs, 

or a passenger in an outboard seating 

position when a CRS is installed in the 

center seating position, we disagree that 

vehicle manufacturers should prevent 

CRSs from being installed in the center 

designated position where no lower 

anchorages exist. Requiring 

manufacturers to prohibit the use of 

CRSs in the center seat when the seat is 

too narrow will eliminate the option for 

parents or caregivers to install the seats 

(with seat belt or with non-standard 

lower anchorages if allowed) in the 

center seat based on their need to 

accommodate all passengers. 

Finally, in response to Dr. Baer’s 

comment raising questions on the 

appropriateness of vehicle manufacturer 

sales practices to families, NHTSA will 

not address this comment as it does not 

relate to the proposals in the NPRM and 

is outside the scope of this rulemaking. 

Requiring Dedicated Center Lower 

Anchorages With Standard Spacing To 

Accommodate Rigid Lower Anchorage 

Attachments 

ARCCA recommended providing 

lower anchorages for the center rear 

occupant position, stating research has 

shown that a CRS properly secured in 

the center rear occupant position 

provides the most effective occupant 

crash protection. ARCCA added that 

research also indicates that CRSs 

secured by CRASs provide superior 

occupant crash protection compared 

with CRSs secured by a seat belt, 

especially in side impacts, and that 

rigid-lower-anchorage-attachmentssecured CRSs provide the greatest 

amount of side impact crash protection. 

ARCCA stated that while the center rear 

seat may not be plausible when there is 

more than one child,142 many couples 

only have one child, and those that have 

more children typically only have one 

initially, so many children can be 

secured in the center rear occupant 

position. 

ARCCA stated that for optimal crash 

protection a child should be properly 

secured in the center rear occupant 

position in a CRS with rigid lower 

anchorage attachments. In addition, 

ARCCA commented that CRSs 

incorporating rigid lower anchorage 

attachments have recently become 

available in the U.S and that parents 

choosing to use these CRSs for the 

increased crash protection should not be 

forced to compromise that crash 

protection by having to place the CRS in 

an outboard location, when the center 

position is available but does not have 

lower anchorages. ARCCA also 

recommended that labels and color 

coding be used to prevent confusion 

over which anchorages correspond to 

each occupant position. ARCCA 

explained that manufacturers integrate 

seat belt anchorages in the same general 

area as the lower anchorages, and that 

the seat belt anchorages are able to 

withstand much higher loads than what 

a lower anchorage sustains when 

restraining a high weight CRS. 

Therefore, ARCCA stated that increasing 

the strength of the lower anchorages is 

also readily technically feasible. 

Agency Decision 

As previously stated, this final rule 

will not require a CRAS in the rear 

center seating position, but will permit 

manufacturers to voluntarily include a 

CRAS in rear center seating positions, or 

recommend a method of attaching CRSs 

using CRASs (sharing outboard anchors) 

in the rear center seat. This approach 

balances safety, ease of use, and design 

flexibility. NHTSA acknowledges 

ARCCA’s recommendation that a 

dedicated center position should be 

available to accommodate CRSs with 

rigid lower anchorage connectors; 

however, as explained previously, a 

dedicated set of anchorages in the center 

seat is not always feasible due to space 

restrictions. Further, CRSs with rigid 

lower anchor connectors make up a very 

small number of CRSs in the field. As 

such, requiring lower anchorages in the 

center seating position to install CRSs 

with rigid lower anchor connectors 

would not add significant benefit as the 

CRS can also be safely installed using 

the seat belt. ARCCA expressed that 

many parents have only one child, or 

one child initially, and stated that they 

should be able to use the center seat for 

installing the CRS. Because center 

seating positions provide seat belts, 

CRSs can be installed in the center seat 

with a seat belt, or, if available, lower 

anchorages; therefore, NHTSA, does not 

see this issue as concerning. As stated 

earlier, parents or caregivers will have 

the option of installing CRSs with rigid 

lower anchor connectors with the seat 

belt in the center seating position or in 

an outboard position where a dedicated 

lower anchorage set should be available. 

Additionally, ARCCA recommended 

labels and color coding be used to 

prevent confusion over which 

anchorages correspond to each occupant 

position. Since NHTSA is not adopting 

any new requirement for additional 

lower anchorages (dedicated or shared), 

NHTSA is not adopting any labels or 

color coding to identify the lower 

anchorages per seating position. As 

NHTSA did not propose any labels and 

color coding to identify the lower 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1331 

143Amenson, T., Sullivan, L.K., ‘‘Dynamic 

Evaluation of LATCH Lower Anchor Spacing 

Requirements and Effect of Tether Anchor Location 

on Tether and Lower Anchor Loads.’’ 

144FMVSS No. 213 will be replaced by FMVSS 

No. 213b on December 5, 2026. 145For example, most CRS manufacturers 

currently prohibit the use of inflatable seat belts 

and the use of their products in a non-front facing 

vehicle seat. Manufacturers stated that their 

products are not certified for those conditions, and, 

therefore, prohibit them (even though research 

shows they perform well with inflatable seat belts 

and in any direction crash). 

146Amenson, T., Sullivan, L.K., ‘‘Dynamic 

Evaluation of LATCH Lower Anchor Spacing 

Requirements and Effect of Tether Anchor Location 

on Tether and Lower Anchor Loads,’’ NHTSA, 

2013. www.regulations.gov/document/NHTSA2014-0123-0004. 

147 76 FR 10637. See www.govinfo.gov/content/ 

pkg/FR-2011-02-25/pdf/2011-4212.pdf. 

anchorages per seating position, 

adopting these requirements for vehicles 

that voluntarily provide additional 

anchorages would fall outside the scope 

of this rulemaking and will thus not be 

addressed by this final rule. 

Finally, increasing the lower 

anchorage strength requirements, as 

suggested by ARCCA, was not addressed 

in the proposed rule and will not be 

addressed as it is out of scope of this 

rulemaking. 

Spacing of Non-Standard Lower 

Anchorages 

Dorel and JPMA stated that virtually 

all CRS designs in the U.S. use flexible 

lower anchor connectors (as opposed to 

rigid), which are capable of installation 

using a child restraint-equipped flexible 

anchorage system with varying vehicle 

center position spacing widths. Dorel 

observed that test data indicate that 

CRASs attached to lower anchorages of 

widths greater than the standard 280 

mm have crashworthiness that performs 

satisfactorily. 

JPMA requested that NHTSA evaluate 

and provide guidance on the potential 

of standardizing the spacing of the nonstandard lower anchorages. JPMA 

suggested having an allowance in the 

standard seat test bench assembly to 

accommodate some distance of spacing. 

JPMA explained this would afford CRS 

manufacturers the opportunity to 

choose whether to allow the use of 

CRASs with their seats and that NHTSA 

could conduct compliance tests if this is 

the case. JPMA requested NHTSA’s 

guidance in determining the nonstandard spacing to allow for the 

potential redesign of the CRAS 

anchorages to accommodate the angular 

pull of the lower anchorages and lower 

anchor connectors during the crash 

testing. 

Britax stated it has not evaluated or 

tested the variety of simulated child seat 

anchorage spacing that might be 

presented by diverse vehicle rear seat 

designs. Britax suggested that the 

analysis presented in the NPRM 143 may 

be useful in providing guidance so that 

the use of simulated child seat 

anchorages requires at least a minimum 

spacing between the simulated child 

seat anchorages. 

Agency Response 

In response to JPMA’s request that 

NHTSA evaluate and provide guidance 

on potentially standardizing the spacing 

of non-standard anchorages (with an 

allowance in the standard seat test 

bench assembly to accommodate greater 

spacing of lower anchorages), NHTSA 

understands this comment to suggest 

that CRS manufacturers would want a 

certification test in FMVSS No. 213 144

with different lower anchorage spacing 

in order to recommend/allow it in their 

manuals. 

NHTSA does not plan to add this 

additional certification test to FMVSS 

No. 213, as the agency’s dynamic front 

and side sled testing showed no 

significant changes to anchorage loads 

or CRS performance that would justify 

these additional test burdens. Were 

NHTSA to require vehicle 

manufacturers to provide a nonstandard lower anchorage center seating 

position (shared or adding a 5th 

anchorage, etc.), it is highly likely that 

CRS manufacturers will prohibit it.145

As such, NHTSA would have imposed 

a burden on vehicle manufacturers for 

features that will not be used. 

In response to JPMA’s request for 

guidance in determining the nonstandard spacing to allow for the 

potential redesign of the lower 

anchorages to accommodate their 

angular pull during the crash testing, 

the agency points out that NHTSAfunded sled tests using non-standard 

lower anchorage spacing showed that 

increasing the lower anchorage spacing 

did not affect the injury measures of the 

dummies used in the frontal and side 

impact sled tests.146 The updated 

standard seat assembly (Docket No. 

NHTSA–2023–0040) for the frontal and 

side impact tests for CRSs per FMVSS 

No. 213b and FMVSS No. 213a, 

respectively, permits changing the 

width of the anchorages with ease. CRS 

manufacturers may voluntarily conduct 

additional testing with greater 

anchorage spacing than the standard 

280 mm to determine whether to permit 

CRS installation in vehicle seats using 

CRASs with anchorage spacing greater 

than 280 mm. 

Finally, regarding Britax’s suggestion 

to use the NPRM data analysis to 

provide guidance to establish at least a 

minimum spacing between the 

simulated child seat anchorages, the 

agency is not currently issuing any 

guidance on non-standard spacing, but 

CRS and vehicle manufacturers may use 

the NPRM’s data analysis to explore 

their own recommendations. 

b. Third Row 

Currently, FMVSS No. 225 requires 

that at least one of the two required 

CRASs be installed at a second-row 

seating position in each vehicle that has 

three or more rows. A number of 

comments to the 2007 LATCH public 

meeting expressed dissatisfaction with 

the number of CRASs present in the 

third row of vehicles. Specifically, some 

commenters stated that consumers 

sometimes purchase vehicles with three 

or more rows to accommodate large 

families but are unable to install all of 

the child restraints with a CRAS 

because the third row does not have 

available systems. 

The agency examined data and 

comments from the February 25, 

2011,147 request for comments on the 

proposed NCAP Vehicle-CRS Fit 

program. The information reviewed 

indicates there is only a small 

percentage (2.4 to 4.5 percent) of 

children in CRSs with internal harness 

(CRSs that would use the lower 

anchorages) using the third row, and 

that the reduced space in the third row 

makes it difficult to fit most rear-facing 

CRSs. 

The NPRM stated that due to the 

lower anchorages (plus tether 

anchorage) weight limit of 29.5 kg (65 

lb) combined weight (CRS + child) and 

car seat use recommendations 

developed by NHTSA and the AAP that 

children should stay in a rear-facing 

CRS for as long as possible, most CRSs 

installed with lower anchorages will be 

rear-facing ones; therefore, the use of the 

lower anchorages in the third-row might 

only be for a relatively short period for 

forward-facing restraints. 

NHTSA’s 2015 NPRM requested 

comment on the following: 

• Whether FMVSS No. 225 should 

require CRASs or tether anchorages in 

all rear seating positions. 

• Would requiring CRASs or tether 

anchorages in all rear seating positions 

meet the need for motor vehicle safety? 

• Would requiring CRASs or tether 

anchorages in all rear seating positions 

protect the public against unreasonable 

risk of death or injury in an accident? 

• Whether FMVSS No. 225 should 

require CRASs in the third row if it is 

not altogether feasible to use rear-facing 

CRSs in the third-row due to reduced 

space in that row. 


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148NSUBS publications: https:// 

crashstats.nhtsa.dot.gov/#!/PublicationList/20. 

149Alliance comments in Docket No. NHTSA– 

2014–0123–0027. 

150As illustrated on figure 24 of Alliance 

Comments. See Docket No. NHTSA–2014–0123– 

0027. Link: www.regulations.gov/comment/NHTSA2014-0123-0027. 

• The likelihood of consumers 

placing rear-facing CRSs in the third 

row, even if CRSs could fit in that row. 

Even if rear-facing child restraints could 

not or would not be installed using 

CRAS in the third row of a vehicle, are 

CRAS needed in the third row for 

forward-facing CRSs? 

• Would an amendment requiring 

CRASs or tether anchorages at some or 

all third-row seating positions meet the 

requirements and considerations of 

section 30111(a) and (b) of the Vehicle 

Safety Act? 

• The feasibility of installing CRASs 

and tether anchorages in some or all rear 

seating positions in vehicles with three 

or more rows. 

Comments 

In response to these questions, three 

commenters (SRN, IIHS, and UMTRI) 

supported requirements for additional 

lower anchorages and/or tether 

anchorages in the third row of vehicles 

(if available). The Alliance stated that 

additional anchorages should be 

optional, and Britax stated that 

additional anchorages systems in the 

third row would not likely result in 

increased harnessed seat installations. 

Support for Tether Anchorages in All 

Rear Seating Positions 

SRN, IIHS, and UMTRI strongly 

recommended requiring tether 

anchorages in every rear seating 

position. IIHS further stated that parents 

have the option of installing a child 

restraint with the vehicle seat belt in 

lieu of lower anchorages, but that there 

is no substitute for a tether anchorage 

when installing a forward-facing child 

restraint. IIHS explained that providing 

parents with a tether anchorage in all 

rear seating positions will not only 

provide additional flexibility in where 

child restraints can be installed, but also 

potentially increase awareness and use 

of tether anchorages, as parents would 

know they could expect to see a tether 

anchorage in every seat. 

Support for Additional CRAS-Equipped 

Seating Positions in the Third Row 

SRN stated that consistently 

providing at least one CRAS for the 

third row would be helpful. SRN 

explained that there are few CRASs 

provided for third rows in vehicles and 

that in MY 2014 vehicles there were 18 

models with at least one CRAS in the 

third row (many of these being full size 

vans that are not typical family 

vehicles). SRN commented that having 

additional CRAS equipped seating 

positions in the third row would ease 

installation in the cramped environment 

of a third row. SRN explained that CRS 

installation in third rows is even more 

difficult than usual as seat belts are 

sometimes anchored to the ceiling and 

back wall, and these types of vehicles 

often have more difficult geometry for 

use with CRS installation and/or are the 

dual-buckle variety that confuses many 

caregivers. 

SRN, IIHS, and UMTRI encouraged 

requiring additional CRASs in the third 

row of vehicles. IIHS stated that the 

NPRM suggested that there may be 

limited benefit for CRAS hardware in 

the third row because of the relatively 

short time that children are in forwardfacing child restraints, but commented 

that CRASs can beneficial longer than 

NHTSA anticipates. IIHS explained that 

according to the most recent National 

Survey on the Use of Booster Seats 

(NSUBS),148 nearly three-quarters of 

children aged 1 to 3 years, almost a 

third of those aged 4 to 5 years, and an 

increasing number of those aged 6 to 7 

years are seated in forward-facing child 

restraints. IIHS added that booster seats 

are increasingly available with lower 

anchorage connectors, increasing the 

likelihood that lower anchorages will be 

used after children transition from the 

forward-facing child restraints to 

boosters. 

UMTRI commented that vehicles with 

more than one row of rear seating 

should be required to have at least two 

sets of lower anchorages and tether 

anchorages at every seating position in 

each row. UMTRI explained that 

families that purchase vehicles with 

multiple rows of seating usually plan to 

have children sit in all the rear seating 

positions at some point during the life 

of the vehicle. Additionally, UMTRI 

stated that even if families are not going 

to use all of the lower anchorages 

simultaneously, it would be beneficial 

for families to have options as their 

needs evolve. UMTRI explained that the 

youngest children might first sit in the 

second row to be closer to adults, and 

that families with a mix of preschool 

and school-aged children might put 

children in harnessed restraints in the 

third row to allow easier ingress and 

egress during carpooling for older 

children using booster seats in the 

second row. 

Support for Optional Anchorages in 

Third Row 

The Alliance commented that the 

installation of child restraint lower 

anchorages in the third row should 

remain optional based on the following 

assertions: 

• The safety belt provides an 

acceptable alternative for restraining a 

harness CRS in the third row. 

• Usage of rear and forward-facing 

harness CRSs in the third row is low; 

data gathered from 87,655 Safe Kids 

Worldwide checklist forms from January 

1, 2013, through December 31, 2013, 

indicate that only 1.7 percent of all 

children sit in the third row in either a 

rear-facing or forward-facing harness 

CRS that could use lower anchorages.149

• Forward-facing harness CRS cannot 

use lower anchorages above a combined 

weight of 65 lbs., which will limit their 

usage of lower anchorages, further 

decreasing the potential usage of lower 

anchorages in the 3rd row. 

The Alliance added that as smaller 

vehicles continue to be introduced for 

fuel economy purposes, it becomes 

difficult, if not impracticable, to install 

a rear-facing CRS in the third row in 

certain of these smaller vehicles due to 

space limitations. The Alliance added 

that even if a rear-facing CRS can be 

fitted in the third row of these smaller 

vehicles, it may not be possible for a 

passenger to be seated in the secondrow seat when a rear-facing CRS is 

installed in the third row.150 The 

Alliance stated that in these cases 

customers will naturally choose to 

install the CRS in the second row rather 

than the third row, rendering the CRAS 

in the third-row unnecessary. 

Britax commented that, according to 

its installation polling, consumers 

frequently cannot easily access thirdrow seats for harnessed child restraint 

installation. Britax explained that rearfacing installation involving children 

under the age of two is even more 

unlikely, as third-row seating tends to 

be relegated to older children who can 

perhaps buckle themselves into booster 

seats or in a belted seat position. Britax 

added that the vehicle interior space 

between many third-row seats and rear 

vehicle doors may prevent the 

installation of either rear-facing 

harnessed seats or tether usage 

generally. Finally, Britax stated that 

mandating anchorage systems in thirdrow seating would not likely result in 

increased harnessed seat installations. 

Agency Response 

After careful consideration the agency 

has decided not to require additional 

lower anchorages or tether anchorages 

in vehicles with more than three rear 

designated seating positions. 


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151NHTSA conducted the National Child 

Restraint Use Special Study (NCRUSS) in 2011, 

observing the use of car seats and booster seats for 

child passengers (birth to 8 years old) in 4,167 

vehicles. The NCRUSS is a nationally 

representative survey. This study found that less 

than 3 percent of children in the study were seated 

in the third row of the vehicle. Greenwell, N.K. 

(2015, May). Results of the national child restraint 

use special study. (Report No. DOT HS 812 142). 

Washington, DC: National Highway Traffic Safety 

Administration. 

152Standard No. 225 (S12) requires vehicle 

manufacturers to provide written instruction for 

using child restraint anchorage systems and tether 

anchorages. Standard No. 213 (S5.6.1) specifies that 

child restraint systems provide printed instructions 

that include a step-by-step procedure for installing 

and securing the child restraint system in a vehicle. 

CRSs equipped with harnesses to 

restrain the child are not widely used in 

the third rows of vehicles,151 which 

supports comments received that for the 

most part forward-facing CRSs and rearfacing CRSs do not fit in third rows 

(without having to make the front seat 

unusable). As these areas are seldomly 

used and seat belts offer a safe 

alternative to install forward-facing 

CRSs to higher combined weights, 

requiring additional lower anchorages 

in the third row offers no significant 

benefit to justify the cost and weight 

added to the vehicle. 

NHTSA acknowledges comments 

made by UMTRI, IIHS, and SRN 

indicating that increased availability in 

lower anchorages and tether anchorages 

in the third row would offer added 

flexibility and options to caregivers 

when installing CRSs. However, we 

agree with comments received that the 

limited space in many third rows would 

make it difficult for a child to have 

enough space to be seated in a rearfacing or forward-facing CRS (without 

making the seat in front unusable by 

pushing it forward or folding the 

seatback), thus limiting the use of third 

rows for transporting children in rearfacing and forward-facing CRSs. The 

agency encourages vehicle 

manufacturers to continue voluntarily 

providing additional lower and tether 

anchorages where feasible, especially in 

vehicles designed for families (e.g., mini 

vans, SUVs) as those consumers would 

likely be seeking the most flexibilities to 

transport children in CRSs. 

c. Terminology 

The agency requested comment on 

whether the written information 152

provided pursuant to Standards No. 225 

and No. 213 using standardized 

terminology referring to the parts of the 

CRAS and the components of the child 

restraint that connect the CRS to the 

vehicle would help improve the ease of 

use of CRAS. 

NHTSA also requested comment on 

whether requiring the following terms 

in child restraint and vehicle user’s 

manuals would help make instructions 

clearer and more uniform: ‘‘lower 

anchor(s)’’ and ‘‘tether anchor’’ for 

components of the vehicle CRAS, and 

‘‘lower anchor attachments’’ and 

‘‘tether’’ for components of the CRS that 

are used to connect the CRS to the 

vehicle. A ‘‘lower anchor attachment’’ is 

comprised of a ‘‘lower anchor 

connector’’ and a ‘‘lower anchor strap’’ 

(for flexible lower anchor attachments), 

and a ‘‘tether’’ is comprised of a ‘‘tether 

hook’’ and a ‘‘tether strap.’’ 

Comments 

Graco recommended that NHTSA 

update FMVSS No. 213 with the same 

terminology for lower anchorages and 

tether anchorage so that there is no 

confusion with how the labels will read 

verses the requirements in the NPRM. 

For example, Graco pointed out that 

currently section S5.5(j) of FMVSS No. 

213 says ‘‘Secure the top anchorage 

strap provided with this child 

restraint.’’ However, according to Graco, 

per the NPRM’s proposal it should say 

‘‘Secure the tether provided with this 

child restraint.’’ Graco also commented 

that section S5.6.1.12(a) of FMVSS No. 

213 says ‘‘Do not use the lower 

anchorages of the CRAS (LATCH 

system) to attach this child restraint 

when restraining a child weighing more 

than . . .’’ Graco asked for clarification 

on whether the term ‘‘(LATCH system)’’ 

should be included in the statement. 

Similarly, Dorel stated that the use of 

the acronym LATCH, as required by 

FMVSS No. 213, can be confusing to 

consumers. Dorel explained that the 

English language’s use of the word 

‘‘LATCH’’ has several meanings, one of 

which describes a device that holds a 

door, gate or window, and another 

referring to a mechanical device that 

engages in order to ‘‘fasten.’’ Dorel 

added that the word LATCH implies a 

single device, and not multiples of 

devices or functions which combined 

make up a system. Dorel explained that 

the plain language use of terms in child 

restraint and vehicle user’s manuals 

should help make the instructions 

clearer and more uniform. Dorel agreed 

that use of plain words such as the 

proposed ‘‘lower anchor(s)’’ and ‘‘tether 

anchor,’’ or ‘‘lower anchor attachments’’ 

and ‘‘tether’’ for components, are in fact 

more descriptive of the word’s intended 

purpose than a single acronym that 

could be confusing. 

Dorel further explained that for 

bilingual members of the U.S. 

population, especially those for whom 

English is a second language or other 

comprehension factors are involved, 

‘‘lower’’ and ‘‘top’’ can be confusing 

language modifiers. By way of example, 

Dorel pointed to mini-vans and SUVs 

that have tether anchorages at the base 

of the vehicle seat or on the floor behind 

the vehicle seat. Dorel explained that 

when the ‘‘lower anchorages’’ are higher 

than the ‘‘top anchorage,’’ 

comprehension can become quite 

challenging. Dorel stated that requiring 

installation diagrams labeled with 

standardized terminology could help 

with comprehension. Britax also 

indicated support for efforts to 

standardize common terminology 

related to anchorage systems and 

requested additional time to incorporate 

such changes into its CRS printed 

materials. SRN agreed that uniform 

terminology would help to make CRAS 

instructions clearer and less confusing. 

SRN stated that given the proposed new 

requirements for instructions explaining 

the new CRAS markings, it seems 

reasonable to make sure that those 

instructions have uniformity of terms. 

SRN added that it is comfortable with 

the terms proposed. 

Dorel stated that standardized 

terminology, combined with associated 

symbols, would improve consumers’ 

ability to comprehend the intended 

function of a system made up of 

separate components. Dorel further 

indicated that this would increase the 

likelihood of the correct use of child 

restraints. UMTRI agreed that the use of 

the term LATCH may mask the 

importance of the tether component of 

the system; however, UMTRI stated that 

avoiding the term LATCH doesn’t 

necessarily reduce confusion, as it has 

been in widespread use for over 16 

years. Similarly, IIHS supported the use 

of consistent terminology and the 

explicit use of the proposed terminology 

in owner’s manuals but encouraged 

NHTSA to continue to allow and 

encourage the term LATCH to refer 

collectively to the dedicated CRAS and 

associated child restraint hardware. 

IIHS explained that changing to new 

terminology at this point in lieu of the 

term LATCH would confuse parents 

with no apparent off-setting benefit. 

IIHS further stated that it is prudent 

to have the ability to refer to all the 

anchorage hardware in one efficient 

phrase, while clearly specifying lower 

anchorages and tether anchorages when 

necessary. IIHS also stated that the 

phrase ‘‘child restraint anchorage 

system’’ is ambiguous and cumbersome 

and does not convey the important 

message that lower anchorages and 

tether anchorages are hardware distinct 

from safety belts, as belts could also be 

considered a CRAS. Finally, IIHS stated 

that the absence of the term LATCH in 


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1334 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

153The NPRM proposed to add the term and 

definition of ‘‘rigid lower anchor attachment’’ 

(which means the child restraint system’s lower 

anchorage connector that is rigid and does not have 

a lower anchorage strap), which also addresses 

comments recommending a standardized term. 

154A ‘‘child restraint anchorage system’’ means a 

vehicle system that is designed for attaching a child 

restraint system to a vehicle at a particular 

designated seating position, consisting of two lower 

anchorages and a tether anchorage. 

155The terminology proposed in the NPRM and 

adopted in this final rule is as follows: ‘‘lower 

anchor(s)’’ and ‘‘tether anchor’’ for components of 

the child restraint anchorage system, and ‘‘lower 

anchor attachments’’ and ‘‘tether’’ for components 

of the CRS that are used to connect the CRS to the 

vehicle. A ‘‘lower anchor attachment’’ is comprised 

of a ‘‘lower anchor connector’’ and a ‘‘lower anchor 

strap’’ (for flexible lower anchor attachments), and 

a ‘‘tether’’ is comprised of a ‘‘tether hook’’ and a 

‘‘tether strap.’’ 

the NPRM and NHTSA’s website might 

suggest the term LATCH is discouraged. 

UMTRI suggested that the term 

LATCH continue to be used, while 

employing additional efforts to 

emphasize the tether component. 

UMTRI stated that some of the 

confusion over the term LATCH stems 

from the requirement by NHTSA to refer 

to LATCH anchorages and connectors as 

the ‘‘child restraint anchorage system.’’ 

UMTRI further stated that if NHTSA 

harmonized terminology and permitted 

the use of the term LATCH in required 

labeling it would do more to reduce 

confusion than discontinuing use of the 

term LATCH. UMTRI also suggested 

requiring vehicle owner’s manuals to 

include language to convey the idea that 

the tether component of the LATCH 

system must be used when installing 

forward-facing car seats using the 

seatbelt. UMTRI explained that many 

vehicle manuals do not mention or 

emphasize this point. 

UMTRI also stated that it would be 

helpful if vehicle manuals included 

directions on how to use and route 

single strap or V-style tethers in relation 

to the vehicle interior components, such 

as head restraints. UMTRI stated it 

preferred the term ‘‘LATCH belt’’ to 

‘‘lower anchor strap,’’ as the word belt 

emphasizes that either the seatbelt or 

the LATCH belts are the primary means 

of attaching the CRS. Finally, IIHS 

stated that standardized terminology 

should include a term for rigid lower 

anchorage connectors, found on several 

booster seats in the U.S. market. 

Agency Response 

The agency acknowledges several 

comments indicating support for a 

standardized terminology and/or 

agreement with the terms proposed in 

the NPRM to have more consistent 

education messages and user manuals to 

improve the ease-of-use of CRASs. The 

agency also acknowledges commenters 

who stated that removing the term 

LATCH could cause more confusion to 

consumers, as parents will have to be reeducated with new terminology. 

This final rule does not prohibit CRS 

or vehicle manufacturers from using the 

term LATCH (a term originally coined 

by industry and retail groups, not the 

agency). However, to help reduce 

potential confusion the agency will now 

require CRS and vehicle owner’s 

manuals to include the standard 

terminology proposed in the NPRM 

when describing the components of the 

CRAS and its connectors.153 This 

decision is being made based in part on 

over 15 years of consumer education 

efforts by the agency, manufacturers, 

and the safety community to clearly 

explain what the term LATCH means 

and to use it consistently. Given the 

ongoing confusion with this term, 

despite these ongoing efforts, it is clear 

consumers still struggle to understand 

the term. Although the standardized 

definitions required by this final rule 

will likely result in a transition period, 

with the need to inform parents and 

CPSTs about the terminology change, 

the new terminology will become 

commonplace and should assist in 

reducing current confusion. 

NHTSA acknowledges UMTRI’s 

statement that some of the confusion 

over the term LATCH stems from the 

requirement by NHTSA to refer to 

LATCH anchorages and connectors as 

the ‘‘child restraint anchorage system.’’ 

However, the term CRAS 154 is not 

widely used in owner’s manuals or any 

education materials, but is instead 

mostly used in the FMVSS No. 213 

required labels. Although the use of the 

term CRAS in FMVSS No. 213 may 

contribute to consumer confusion, the 

agency does not believe it is the 

predominant reason for the confusion as 

most other sources (such as manuals, 

voluntarily labels, education material, 

advertising material) typically use the 

term LATCH. Specifically, confusion is 

primarily created when referring to a 

LATCH installation because of different 

views on what the term means during 

everyday use. For example, to some 

consumers it may mean using the lower 

anchor installation, but not necessarily 

with the tether, as it may be a CRS that 

can be installed rear-facing where the 

tether is not used, or because they do 

not know that the tether should be used 

in a forward-facing CRS. To others, a 

LATCH installation may mean that the 

CRS is installed with the lower anchors 

and the tether. Therefore, under this 

understanding of the term, for CRSs that 

can be installed rear-facing (typically 

installed without a tether), a LATCH 

installation reference may not be 

appropriate. 

NHTSA agrees with Graco’s 

suggestion to update FMVSS No. 213 

with the same terminology for lower 

anchorages and tether anchorage so that 

there is no confusion with how the 

labels will read versus the requirements 

in the NPRM, as the current regulatory 

text in FMVSS No. 213 calls for the use 

of child restraint anchorage systems in 

some instances. This final rule will 

update the required label text to reflect 

the new terminology proposed in the 

NPRM.155 This decision also addresses 

UMTRI’s comments regarding potential 

confusion over the term LATCH and 

child restraint anchorage systems in the 

required labeling text in FMVSS No. 

213. NHTSA notes that in the standards’ 

regulatory text, other than information 

presented to the consumer through 

labels or instruction manuals, the term 

anchorage will continue to be used, as 

it is part of the child restraint anchorage 

system. Further, as discussed below in 

the ‘‘Housekeeping’’ section of this final 

rule, the regulatory text required in 

FMVSS No. 225 that currently uses the 

term LATCH will be deleted from the 

standard per this final rule, as those 

sections are no longer active. 

In response to UMTRI’s suggestion to 

use the term ‘‘LATCH belt’’ instead of 

‘‘lower anchor strap,’’ NHTSA disagrees 

with this suggestion, as the term ‘‘strap’’ 

is more often used when referring to the 

lower anchor strap and the agency has 

no information on whether the term 

‘‘belt’’ instead of ‘‘strap’’ would have the 

effect of emphasizing that either the 

seatbelt or the LATCH belt are the 

primary means of attaching the CRS, as 

UMTRI expects. Further, FMVSS No. 

213 & 213b standards currently have 

required labeling statements which use 

the word strap, so it would also promote 

consistency instead of introducing a 

different term. Finally, in response to 

UMTRI’s recommendation to include 

required written instructions on how to 

use the V-tether straps and to use the 

tether with CRSs installed with seat 

belt, these comments are outside the 

scope of the NPRM’s proposals and will 

therefore not be addressed as they fall 

outside the scope of this rulemaking. 

d. Recommendation for Tether 

Anchorage Use Regardless of Child 

Weight 

NHTSA requested comment on the 

merits of an instruction to consumers to 

use the tether to install all forwardfacing child restraints with internal 

harnesses, whether installed with lower 


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156Legault, F. Garndner, B., Vincent, A., ‘‘The 

Effect of Top Tether Strap Configurations on Child 

Restraint Performance,’’ Society of Automotive 

Engineers, SAE No. 973304, 1997. In addition, the 

quantifiable safety benefits that NHTSA estimated 

will accrue from the LATCH rulemaking was due 

to the tether. 

157FMVSS No. 225, ‘‘Child restraint systems,’’ 

established lower anchorage strength requirements 

developed to ensure that the vehicle child restraint 

anchorage system would be able to withstand forces 

resulting from a 65 lb mass in a severe crash of a 

vehicle into a rigid barrier. 

anchorages or seat belt, regardless of 

child weight. 

The 2015 NPRM explained that a 

simple instruction would increase the 

ease-of-use of the tether, resulting in a 

decrease in injuries. The NPRM also 

presented data indicating that tether 

anchorages are already reasonably 

robust to withstand crash forces, and 

that the benefits of tether use for all 

children in the subject CRSs (regardless 

of child weight) outweigh the potential 

risks occurring from tether anchorage 

failure due to a higher combined weight 

and/or a higher severity crash. 

Comments 

Several commenters, including Graco, 

JPMA and UMTRI, supported the 

NPRM’s recommendation that forwardfacing CRSs should always be used with 

the tether. Graco agreed that the 

consumer should be advised to attach 

the tether when restraining a child in a 

harness CRS, regardless of the weight of 

the child. Graco explained that the 

limiting factor for structural strength is 

the CRS, which generally has a tether 

anchorage point in the plastic seat shell, 

and that crash energy dissipation can be 

had by the deformation of the plastic 

shell, reducing the energy going to the 

child while at the same time reducing 

the displacement of the child. 

UMTRI stated that the potential 

benefits of the tether in a range of 

crashes far outweigh the hypothetical 

risks of injury due to a tether anchorage 

failure that has never been documented 

in a real-world crash and has only been 

demonstrated in a very small number of 

high-severity crash tests (less than 5). 

Only one commenter, the Alliance, 

stated that it would be inappropriate for 

the agency to issue blanket instructions 

for consumers to use tethers with all 

children restrained in forward-facing 

CRS without providing some limits on 

both the child and CRS weight. The 

Alliance further explained that its 

members have differing opinions 

regarding use of tethers for child/CRS 

combinations in excess of 65 pounds 

based on internal testing and analysis 

conducted by each member company. 

The Alliance stated that when the 

current strength limits were developed 

for FMVSS No. 225, the agency made 

certain assumptions about the size and 

weight of the child/CRS combination, 

and that NHTSA originally considered a 

combined child and child restraint 

weight of 65 pounds when defining the 

strength requirements. The Alliance 

stated that its members agree that the 65 

pounds combined weight limit is 

appropriate for child restraints secured 

with the lower and tether anchorages, 

but do not all agree that the same weight 

limit should be applied to a child 

restraint that uses a tether to 

supplement the seat belts for 

attachment. 

The Alliance stated that the strength 

requirements specified in the current 

regulation are appropriate to assess 

anchorage strength in the regulation, 

since it is a repeatable test method and 

provides an appropriate design margin, 

given the rate-sensitive properties of the 

anchorages that result in increased loadcarrying capabilities in real-world, 

short-duration crash pulses. However, 

the Alliance explained that the 

relationship between static and dynamic 

strength is dependent on the design of 

the system, including materials, 

geometry and attachment method. The 

Alliance added that the issue is further 

exacerbated by the lack of limits within 

FMVSS No. 213 on the size, weight, and 

capacity of the child restraints the 

anchorages are intended to restrain. 

The Alliance further stated that while 

NHTSA references test data in the 

NPRM indicating many vehicles have 

tether anchorage strength that exceeds 

the FMVSS No. 225 regulatory static 

strength requirements, the agency has 

not tested every vehicle combination. 

The Alliance pointed out that while 

results from dynamic testing conducted 

by Transport Canada (referenced in the 

NPRM), are encouraging, this testing did 

not include all vehicle designs. 

The Alliance stated it is well known 

that certain vehicles, based on their 

layout, have significant structure 

available to support tether anchorages, 

and thus might have a large compliance 

margin; however, the Alliance stated 

there may be vehicles which have to 

place the anchorages in locations with 

limited structural support. As a result, 

the Alliance explained that 

manufacturers may have to redesign 

those systems to add additional 

strength, which would impose 

additional cost and weight exceeding 

the values anticipated (and accepted by 

OMB) in the original rulemaking 

proposal. The Alliance added that tether 

anchorages located in the middle of 

seatbacks might have to move to the 

floor, pillars, or roof to meet higher 

loading requirements, conflicting with 

the goal to locate anchorages in uniform, 

easily accessible positions such as the 

center of the seatback. 

The Alliance requested that if the 

agency does impose such a requirement 

for all vehicles, it must also impose a 

weight limit for CRSs, and/or require 

CRSs above a certain weight and 

designed for use by heavier children to 

include load limiting features on their 

tether anchorage attachment hardware. 

The Alliance also stated the new usage 

requirement must only apply to new 

vehicles, pointing out that it cannot be 

retroactive to all vehicles already in the 

field. 

Agency Response 

This final rule will implement the 

NPRM’s proposal to develop simple 

education materials to promote the use 

of the tether when a tether and a tether 

anchorage are available. The agency 

made this decision following review of 

comments received. Most commenters, 

including JPMA, Graco, and UMTRI, 

expressed support for the NPRM’s 

proposal to promote tether use by 

recommending its use in all forwardfacing CRSs, whether installed using 

lower anchorages or seat belts, via a 

simple and uniform instruction. 

Analysis of NHTSA’s crash data files 

shows that the most common moderate 

to higher severity injuries among 

children restrained in rear seats are to 

the head and face and the most common 

contacts for these injuries to children 

are the seat and back support. Sled test 

data indicates that use of the upper 

tether reduces head excursions of the 

occupant restrained in the CRS and 

therefore, reduces the likelihood of head 

impacts against the vehicle structure.156

Tether use may particularly benefit 

taller children since they may 

experience greater head excursion than 

children with shorter seated height. 

The 2015 NPRM noted that 99.4 

percent of crashes involving restrained 

children occur at change in velocities 

less than 30 mph and that for a majority 

of these crashes the loads on the tether 

anchor would be lower than the 

required strength per FMVSS No. 225, 

even if the child restraint and child 

combined weight exceeds 65 lb.157 The 

NPRM noted that a forward-facing child 

restraint with tether attached would 

reduce the risk of head excursion and 

subsequent head contact and head 

injuries to the child in crashes with 

change in velocity less than 30 mph, 

which are the most common injury 

types to CRS restrained children. 


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1336 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

158 In the 2012 final rule the CRS was required 

to have the statement: ‘‘Do not use the lower 

anchors of the child restraint anchorage system 

(LATCH system) to attach this child restraint when 

restraining a child weighing more than _*_with 

internal harness of the child restraint,’’ where ‘‘*’’ 

is a value where the sum of the recommended child 

weight and the weight of the child restraint system 

do not exceed 65 pounds (29.5 kg). 

159 In the 2014 final rule the CRS was required 

to have an installation diagram of the CRS using the 

lower anchorages with the statement ‘‘Do not install 

by this method for a child weighing more than _*_,’’ 

where ‘‘*’’ is the child weight limit in accordance 

with tables described in the standard. The tables 

were based on a 65 lb combined weight but give 

some allowances to allow manufacturers to round 

the child weight limit and maximize lower 

anchorage use. 

160Thus, the combined weight of CRS + child 

should not exceed 29.5 kg (65 lb) on the lower 

anchorages. 

161Research indicates that only about half of 

vehicle owners read their owner’s manual. 

162On September 17, 2024, the agency published 

an NPRM (89 FR 76035) proposing to remove the 

retrofit air bag on-off switch sunset date. The agency 

is not removing the sunset of air bag on-off switches 

in production vehicles. 

163Compliance date is the date by which 

manufacturers must demonstrate adherence to the 

regulation. Effective date is the date when the CFR 

is amended by following the instructions in a final 

rule. 

The 2012 (77 FR 11626) 158 and 2014 

(79 FR 10396) 159 final rules adopted 

labeling requirements into FMVSS No. 

213, ‘‘Child restraint systems,’’ to 

inform the consumer when to stop 

installing a CRS using the lower 

anchorage attachments. These 

requirements consisted of calculating 

the maximum child weight a CRS could 

be used for when it is installed with the 

lower anchorages, based on the 

maximum combined weight (CRS 

weight + child weight) of 65 lb. 

While the 2012 and 2014 final rules 

established a child weight limit for CRS 

lower anchorage installation, NHTSA 

did not adopt any requirements 

establishing a weight limit for tether use 

or issue any recommendations of tether 

use, as the agency needed more research 

to evaluate the potential benefits and 

risks. The tether supplements the 

primary attachment of the CRS to the 

vehicle seat (the primary attachment is 

accomplished by the lower anchorages 

of the child restraint anchorage system 

or by the vehicle seat belt). The primary 

attachment of the CRS to the vehicle 

should never fail in a crash since its 

integrity is needed to avoid a 

catastrophic uncoupling of the CRS 

from the vehicle.160 The tether 

anchorage is a supplemental attachment 

point that enhances the safety of the 

CRS by reducing head excursions. 

Additionally, when the lower 

anchorages cannot be used to install a 

CRS due to the combined weight of the 

child and CRS exceeding the weight 

limit, the CRS can be installed using the 

vehicle’s seat belt. However, even when 

the vehicle seat belt is used instead of 

the lower anchorages the tether 

anchorage should still be used. 

As noted in the NPRM, crash test and 

quasi-static test data indicates that many 

tether anchorages in current vehicles 

can withstand the loads imparted in 

crashes up to 56 km/h by a CRS 

restraining 6-year-old and 10-year-old 

crash test dummies. These measured 

loads imparted to the tether anchorage 

represent the upper limit of expected 

tether anchorage loads in nearly all realworld crashes involving children 

restrained in CRSs. NHTSA has 

monitored field data for injuries 

resulting from tether anchorage failures 

due to excess loads in a crash and 

believes that such an event is very rare 

and any potential injury risk resulting 

from such an event is small. 

NHTSA acknowledges the Alliance’s 

comments expressing concerns over the 

NPRM’s request for comment regarding 

consumer information to always use the 

tether for forward-facing CRSs 

regardless of child weight or attachment 

method (lower anchorages or seat belt). 

However, the organization did not 

provide any data suggesting the risk of 

tether anchorage failure outweighs any 

benefits of the use of the tether 

anchorage. 

NHTSA disagrees with the Alliance’s 

comments that (1) manufacturers would 

have to redesign some of their tether 

anchorage systems to support additional 

strength, which would impose 

additional cost and weight that would 

exceed the values anticipated in the 

original rulemaking proposal; and (2) 

the requirement cannot be retroactive to 

all vehicles already in the field. The 

agency is not requiring vehicle 

manufacturers to comply with a higher 

strength requirement on the tether 

anchorages. Instead, NHTSA is 

recommending consumers always use a 

tether (when available in CRS and 

vehicle seating position) when installing 

forward-facing CRSs to enhance the 

safety of all children in CRSs. Further, 

the required label on the CRS specifying 

the child and CRS weight limit only 

applies to the use of the lower 

anchorages for installing the CRS in the 

vehicle. This combined child and CRS 

weight limit does not apply to the use 

of tether anchorages when the CRS is 

installed using seat belts or the lower 

anchorages. 

NHTSA is aware that since the 

publication of the 2012 final rule some 

vehicle manufacturers have applied the 

lower anchorage weight limit to the 

tether anchorages or to the full child 

restraint anchorage system (lower 

anchorages and tether) in the vehicle 

owner’s manual. However, NHTSA 

points out that the 2012 final rule did 

not impose any child weight restrictions 

for the use of the tether anchorages. 

The agency believes that the increased 

use of tethers expected from these 

uniform and simple instructions will 

help minimize injuries in most crashes 

involving children where the loads to 

the tether would be within the required 

strength requirements. Specifically, a 

single consistent statement will promote 

tether use.161 Therefore, the agency’s 

recommendation for best protection is to 

always use the tether when installing a 

forward-facing CRS. 

X. Housekeeping 

Section 5(c) of the FMVSS No. 225 

current standard has sections that refer 

to requirements for vehicles with an air 

bag on-off switch. However, the air bag 

on-off switch requirements in Section 

4.5.4 of FMVSS No. 208; ‘‘Occupant 

crash protection,’’ ceased to be in effect 

on September 1, 2012, and, therefore, 

are no longer available in production 

vehicles.162 As such, this final rule is 

revising section 5(c) to remove the 

obsolete requirements. 

XI. Lead Time and Phase-In 

In the 2015 NPRM, NHTSA proposed 

a compliance date 163 3 years after the 

final rule is published. NHTSA noted 3 

years would provide sufficient time for 

vehicle manufacturers to accommodate 

any redesign of the vehicle seat in their 

normal course of vehicle design cycles 

without a cost increase. Additionally, 

the agency considered the 3-year lead 

time sufficient for child restraint 

manufacturers to comply with the 

proposed tether hardware length limit. 

Comments on Lead Time for Vehicles 

Global, Ford, Toyota, Alliance, FCA, 

and Honda stated that the proposed lead 

time was insufficient. The commenters 

provided several reasons in support of 

a longer lead time, including that design 

changes needed to meet the proposed 

requirements would involve significant 

design changes, body structure 

reinforcement and re-design, changes to 

tether anchorage markings on plastic 

base/cover, changes to the seat and 

anchorages, and, in some cases, 

development of new attachment 

schemes. 

Global and Toyota commented on the 

need to redesign the package shelf, 

located behind the rearmost row of 

seats. Global and Toyota stated that 

package shelf speakers would need to be 

relocated to accommodate the tether 

anchorage beyond the 165-mm proposed 

requirement. Global stated that center 


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164The final rule was published in March 1999 

and the phase-in period for the tether was 

September 1, 1999, through September 1, 2000. For 

the lower anchorages, the phase-in period was 

September 1, 2000, through September 1, 2002. 

seating positions in second and third 

rows would implicate significant design 

changes. Ford indicated that these 

changes would require design and 

tooling changes outside the normal 

product design cycle. 

Commenters proposed adding a 

phased schedule for all new vehicle 

models to meet the new requirements, 

lasting from two to four years. 

Specifically, Global suggested a 

compliance date four years after the date 

of final rule publication, followed by an 

additional two-year phase-in period for 

each manufacturer to achieve 100 

percent compliance. Toyota suggested 

delaying start of compliance at least four 

years from the September 1 following 

the publication of the final rule, 

followed by a three-year phase-in 

period. Under Toyota’s phase-in 

schedule, twenty percent of a 

manufacturer’s vehicles would need to 

comply the first year, fifty percent the 

second year, and one hundred percent 

in the final year, similar to what was 

used in the rulemaking for FMVSS No. 

225 in 1999. FCA requested a three-year 

compliance date followed by four-year 

phase-in, with credits permitted. Honda 

recommended a three-year effective date 

followed by a three-year phase-in with 

percentages equal to Toyota’s proposal. 

Toyota and the Alliance stated that 

the compliance dates should not deviate 

from September 1 (typical MY 

changeover). FCA remarked that a 

longer lead time would reduce the 

overall cost and not cause significant 

delays in a vehicle program. 

Agency Response 

The NPRM proposed a 3-year lead 

time to provide sufficient time for 

vehicle manufacturers to accommodate 

any redesign of the vehicle seat in their 

normal course of manufacture without a 

cost increase. However, the agency 

acknowledges multiple NPRM 

comments indicating that significant 

design changes, such as body structure 

reinforcement and re-design, changes to 

the seat and anchorages, and, in some 

cases, development of new attachment 

schemes, would be necessary to meet 

the proposed requirements. Based on 

these concerns, several commenters 

indicated the need for significantly 

more time than the proposed 3-year lead 

time to redesign their vehicles to meet 

the proposed rule. After full 

consideration of the comments received, 

NHTSA agrees with the request for a 

longer compliance lead time followed 

by a phase-in period for vehicle 

requirements. 

When FMVSS No. 225 was 

introduced, the final rule contained a 

compliance phase-in for the tether 

anchorages that started 1.5 years after 

the rule was published and 2.5 years for 

the lower anchorages.164 In response to 

petitions for reconsideration of that final 

rule, the agency granted extensions and 

temporary alternative options to comply 

with the standard. Based on the changes 

proposed in this final rule, a 3-year 

phase-in schedule that begins at least 

three years after the publication of the 

final rule should provide manufacturers 

with similar relief as the schedule that 

took place with the adoption of FMVSS 

No. 225. The 3-year phase-in will begin 

on the first September 1 that is 3 years 

after publication of the final rule. In the 

first year of the phase-in, a minimum of 

20 percent of each manufacturer’s 

applicable vehicles produced during 

that 1-year period will be required to 

meet the updated standard, followed by 

50 percent of the applicable vehicle 

production in the second year, and 100 

percent of applicable vehicle production 

in the third year and later. 

Providing a 3-year phase-in period for 

complying with the final rule, following 

a lead time of at least 3 years, will 

provide sufficient time for vehicle 

manufacturers to accommodate any 

redesign of the vehicle seat, rear shelf 

structures, and other components in the 

vehicle in their normal course of design 

and manufacture without a cost 

increase. 

NHTSA will remove the exceptions in 

current S5(a) and S5(e) as discussed in 

section VIII of this final rule starting on 

the first September 1 that is six years 

after publication of the final rule. After 

this date convertible vehicles will be 

required to be equipped with tether 

anchorages, and all applicable vehicles, 

with no exceptions, will be required to 

provide lower anchorages. This lead 

time will give manufacturers time to 

update their vehicle designs within 

their design cycles and potentially 

incorporate the change within the same 

cycle as the rest of the requirements. 

Comments on Lead Time for CRSs 

In response to the proposed 3-year 

lead time for CRSs, Britax and JPMA 

stated that a three-year implementation 

period from the adoption of a final rule 

is necessary to make tooling changes for 

the metal components of the tether 

anchorages and/or to ensure that tethers 

in CRSs are assembled with tags 

displaying this symbol as well as to 

facilitate incorporating the revisions to 

CRS printed materials. 

Dorel agreed that 3 years is sufficient 

lead time to meet the proposed FMVSS 

No. 213 requirements. Dorel asked that 

an early compliance option to the new 

standard be available from the date of 

publication of the final rule for both 

vehicle and CRS manufacturers to 

further incentivize early compliance 

and ease-of-use claims to the new 

standard. 

The agency did not receive comments 

in opposition to the proposed lead time 

for CRS requirement updates. 

Agency Response 

This final rule provides a 3-year lead 

time with no phase-in period for CRS 

manufacturers, as proposed, to give 

enough time to redesign, make tooling 

changes, and include markings. 

XII. Cost Benefit Analysis 

The agency estimates that the adopted 

requirements for improved usability of 

CRASs would not result in any increase 

in material cost but would entail some 

redesign of vehicle seat features. 

Approximately 79 percent of vehicles 

would need some redesign to meet the 

proposed lower anchorage usability 

requirements. Some lower anchorages 

would need to be repositioned or the 

trim and structures around them 

modified to meet the clearance angle 

and lower anchorage depth 

requirements adopted in this final rule. 

Some tether anchorages would have to 

be repositioned farther from the head 

restraint to meet the minimum strap 

wrap-around distance requirement. 

Based on feedback received, this final 

rule is providing a 3-year phase-in 

period following a 3-year lead time that 

starts on the first September 1 after the 

publication of the final rule, for 

manufacturers to comply with the final 

rule. This lead time will provide 

sufficient time for vehicle 

manufacturers to accommodate any 

needed redesign of the vehicle seat and 

rear shelf structures into their normal 

course of design and manufacture, 

without a cost increase. 

For child restraints, the agency 

estimates that approximately 30 percent 

of forward-facing child restraints may 

need minor modification to the tether 

hardware assembly to meet the 165 mm 

(6.5 in) maximum length requirement, 

such as changing the supplier to other 

available tether hardware models. 

Minimal or no costs are expected from 

this change as many available tether 

designs are available in the market. 

In relation to this final rule’s 

requirement that all lower anchorages 

and tether anchorages must be marked 

with the ISO symbol, we estimate the 

cost of ISO markings for a set of lower 


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165 44 FR 11034 (Feb. 26, 1979). 

anchorages to be $0.07 and that for the 

tether anchorage to be $0.03. The total 

incremental estimated cost of equipping 

all CRASs with appropriate ISO 

markings is approximately $0.76 

million. The final rule also requires 

similar ISO markings on child restraint 

anchorage connectors, for which the 

agency estimates an incremental cost of 

$0.97 million. The cost of changing the 

written instructions accompanying the 

vehicle or the CRS to explain the ISO 

markings is expected to be negligible 

(less than $0.01). Therefore, the total 

cost of the final rule is estimated to be 

$1.73 million. 

In relation to the benefits of this 

proposed rule, the new usability 

requirements will improve correct 

(tight) installation and increase tether 

use. If the changes required by this final 

rule provide a 5 percent increase in 

correct installation using the lower 

anchorages and a 5 percent increase in 

tether use, the agency estimates that the 

proposed requirements would save 

approximately 3 lives and prevent 6 

moderate to higher severity injuries 

annually. 

XIII. Regulatory Notices and Analyses 

Executive Order 12866, Executive Order 

14904, Executive Order 13563, and DOT 

Regulatory Policies and Procedures 

NHTSA has considered the potential 

impact of this final rule under Executive 

Order 12866, Executive Order 14094, 

Executive Order 13563, DOT Order 

2100.6A, and the Department of 

Transportation’s regulatory policies and 

procedures. This final rule is not 

considered to be significant under the 

Department of Transportation’s 

regulatory policies and procedures.165

This final rule makes several changes 

to FMVSS No. 225 and FMVSS No. 213b 

by specifying additional requirements 

for CRAS and CRSs to improve ease-ofuse of CRAS and improve the likelihood 

that CRSs will be correctly used in 

vehicles. The agency estimates that the 

adopted requirements for improved 

usability of CRASs would not result in 

any increase in material cost but would 

entail some redesign of vehicle seat 

features. 

Specifically, NHTSA is providing a 3- 

year phase-in period following a 3-year 

lead time that starts on the first 

September 1 after the publication of the 

final rule for complying with the final 

rule. We believe this lead-time and 

phase-in schedule will provide 

sufficient time for vehicle 

manufacturers to accommodate any 

redesign of the vehicle seat and rear 

shelf structures into their normal course 

of design and manufacture without 

increased cost. NHTSA is also providing 

an additional 3-year lead time for 

removing some exclusions for providing 

lower anchorages and tether anchorages 

in some vehicles. We estimate a total 

cost of $1.73 million for the 

requirements for markings to identify 

and locate CRAS in vehicles. 

More information can be found in the 

‘‘Cost Benefit Analysis’’ section above. 

The minimal impacts of this final rule 

did not warrant the preparation of a 

regulatory evaluation. 

Regulatory Flexibility Act 

Pursuant to the Regulatory Flexibility 

Act (5 U.S.C. 601 et seq., as amended by 

the Small Business Regulatory 

Enforcement Fairness Act (SBREFA) of 

1996), whenever an agency is required 

to publish a notice of rulemaking for 

any proposed or final rule, it must 

prepare and make available for public 

comment a regulatory flexibility 

analysis that describes the effect of the 

rule on small entities (i.e., small 

businesses, small organizations, and 

small governmental jurisdictions). The 

Small Business Administration’s 

regulations at 13 CFR part 121 define a 

small business, in part, as a business 

entity ‘‘which operates primarily within 

the United States.’’ (13 CFR 121.105(a)). 

No regulatory flexibility analysis is 

required if the head of an agency 

certifies that the rule will not have a 

significant economic impact on a 

substantial number of small entities. 

The SBREFA amended the Regulatory 

Flexibility Act to require federal 

agencies to provide a statement of the 

factual basis for certifying that a rule 

will not have a significant economic 

impact on a substantial number of small 

entities. NHTSA has evaluated the 

effects of this action on small entities. 

I hereby certify that this final rule will 

not have a significant economic impact 

on a substantial number of small 

entities. This final rule specifies 

additional requirements for CRAS and 

CRSs to improve ease-of-use of CRAS 

and to improve the likelihood that CRSs 

will be correctly used in vehicles. The 

final rule provides a 3-year lead start 

time, followed by a 3-year phase-in 

period for complying with the final rule 

that would provide sufficient time for 

small manufacturers to modify designs 

within normal design cycles, and 

thereby not incur additional 

manufacturing costs. 

NHTSA estimates there are 38 

manufacturers of child restraints, none 

of which are small businesses. Even if 

there were a small CRS manufacturer, 

the impacts of this proposed rule would 

not be significant. This final rule adopts 

minor changes to the requirements 

applying to CRSs. The requirements are: 

Limiting the length of the tether 

hardware assembly (tether hook and 

tightening mechanism) to 165 mm (6.5 

in) (UMTRI estimated that about 30 

percent of CRS models might need some 

changes to the tether hardware assembly 

to meet the 165 mm (6.5 in) limit), 

marking the lower anchorage connectors 

and the tether hook or tether strap with 

the ISO marking, and changing written 

instructions provided to the owners to 

include the defined terms and 

instruction on using the tether. These 

are minor changes that do not affect the 

shell or any other structure of the child 

restraint. We believe that there would be 

no incremental cost due to limiting the 

tether hardware assembly to 165 mm 

(6.5 in) since the tether hardware 

assembly costs would not increase 

because of the requirement. We estimate 

that the cost of marking the CRS child 

restraint anchorage connectors would be 

about $0.07 per set of lower anchorage 

connectors and $0.04 per tether hook. 

Changing the written instructions 

accompanying CRSs would be negligible 

(significantly less than $0.01). 

NHTSA is aware of six vehicle 

manufacturers that may be categorized 

as small businesses. However, the 

proposed rule will not have a significant 

economic impact on these 

manufacturers, as vehicles produced by 

these small manufacturers already have 

to provide child restraint anchorage 

systems and tether anchorages meeting 

FMVSS No. 225, unless the vehicle is 

excluded from the standard. The 

changes proposed in this NPRM only 

adjust the physical features of the 

anchorage systems, adjustments which 

should have a positive impact on the 

ease of use of the systems, but that are 

small in terms of affecting the overall 

configuration of current anchorage 

systems. We estimate the cost of 

marking the lower anchorages and the 

tether anchorages to be less than 

approximately $0.16 (depending on the 

number of anchorages in the vehicle) 

per vehicle. The cost of changing the 

written instructions accompanying the 

vehicle would be negligible, less than 

$0.01. 

This rule may also affect final stage 

manufacturers and alterers, many of 

whom would be small businesses. 

However, NHTSA believes that the 

impacts of this final rule on such 

entities would not be significant. Finalstage manufacturers or alterers installing 

rear seats in vehicles subject to FMVSS 

No. 225 must already provide child 

restraint anchorage systems and tether 

anchorages meeting FMVSS No. 225. 


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We believe that the changes adopted in 

this final rule only make small 

adjustments to the physical features of 

the anchorage systems, adjustments that 

should have a positive impact on the 

ease of use of the systems, but that are 

minor in terms of the impact on the 

configuration of current anchorage 

systems. We estimate the cost of 

marking the lower anchorages and the 

tether anchorages would be less than 

$0.16 per vehicle (depending on the 

number of anchorages in the vehicle). 

The cost of changing the written 

instructions accompanying the vehicle 

would be negligible (significantly less 

than $0.01 per vehicle). 

Federalism 

NHTSA has examined this final rule 

pursuant to E.O. 13132 (64 FR 43255, 

August 10, 1999) and concluded that no 

additional consultation with states, 

local governments, or their 

representatives is mandated beyond the 

rulemaking process. The agency has 

concluded that the rulemaking would 

not have sufficient federalism 

implications to warrant consultation 

with state and local officials or the 

preparation of a federalism summary 

impact statement. This final rule would 

not have ‘‘substantial direct effects on 

the States, on the relationship between 

the national government and the States, 

or on the distribution of power and 

responsibilities among the various 

levels of government.’’ 

NHTSA rules can have a preemptive 

effect in two ways. First, the National 

Traffic and Motor Vehicle Safety Act 

contains an express preemption 

provision: When a motor vehicle safety 

standard is in effect under this chapter, 

a state or a political subdivision of a 

state may prescribe or continue in effect 

a standard applicable to the same aspect 

of performance of a motor vehicle or 

motor vehicle equipment only if the 

standard is identical to the standard 

prescribed under this chapter. 49 U.S.C. 

30103(b)(1). It is this statutory command 

by Congress that preempts any nonidentical state legislative and 

administrative law address the same 

aspect of performance. 

The express preemption provision 

described above is subject to a savings 

clause under which ‘‘[c]ompliance with 

a motor vehicle safety standard 

prescribed under this chapter does not 

exempt a person from liability at 

common law.’’ 49 U.S.C. 30103(e). 

Pursuant to this provision, state 

common law tort causes of action 

against motor vehicle manufacturers 

that might otherwise be preempted by 

the express preemption provision are 

generally preserved. 

NHTSA rules can also preempt state 

law if complying with the FMVSS 

would render the motor vehicle 

manufacturers liable under state tort 

law. Because most NHTSA standards 

established by an FMVSS are minimum 

standards, a state common law tort 

cause of action that seeks to impose a 

higher standard on motor vehicle 

manufacturers will generally not be 

preempted. However, if and when such 

a conflict does exist—for example, when 

the standard at issue is both a minimum 

and a maximum standard—the state 

common law tort cause of action is 

impliedly preempted. See Geier v. 

American Honda Motor Co., 529 U.S. 

861 (2000). 

Pursuant to E.O. 13132, NHTSA has 

considered whether this final rule could 

or should preempt state common law 

causes of action. The agency’s ability to 

announce its conclusion regarding the 

preemptive effect of one of its rules 

reduces the likelihood that preemption 

will be an issue in any subsequent tort 

litigation. To this end, the agency has 

examined the nature (e.g., the language 

and structure of the regulatory text) and 

objectives of this final rule and finds 

that this final rule, like many NHTSA 

rules, prescribes only a minimum safety 

standard. 

Accordingly, NHTSA does not intend 

that this final rule preempt state tort law 

that would effectively impose a higher 

standard on motor vehicle 

manufacturers than that established by 

this final rule. Establishment of a higher 

standard by means of state tort law 

would not conflict with the minimum 

standard finalized in this document. 

Without any conflict, there could not be 

any implied preemption of a state 

common law tort cause of action. 

National Environmental Policy Act 

NHTSA has analyzed this rule for the 

purposes of the National Environmental 

Policy Act. In accordance with 49 CFR 

1.81, 42 U.S.C. 4336, and DOT NEPA 

Order 5610.1C, NHTSA has determined 

that this rule is categorically excluded 

pursuant to 23 CFR 771.118(c)(4), 

(planning and administrative activities, 

such as promulgation of rules, that do 

not involve or lead directly to 

construction). This rulemaking, which 

amends Federal Motor Vehicle Safety 

Standard (FMVSS) No. 225, ‘‘Child 

Restraint Anchorage Systems,’’ and 

FMVSS No. 213b, ‘‘Child Restraint 

Systems,’’ to improve ease-of-use of the 

lower and tether anchorages, improve 

correct use of child restraint systems in 

vehicles, and maintain or improve the 

correct use and effectiveness of child 

restraint systems (CRSs) in motor 

vehicles, is not anticipated to result in 

any environmental impacts, and there 

are no extraordinary circumstances 

present in connection with this 

rulemaking. 

Paperwork Reduction Act (PRA) 

Under the procedures established by 

the Paperwork Reduction Act of 1995 

(PRA) (44 U.S.C. 3501, et seq.), a Federal 

agency must request and receive 

approval from the Office of Management 

and Budget (OMB) before it collects 

certain information from the public and 

a person is not required to respond to 

a collection of information by a Federal 

agency unless the collection displays a 

valid OMB control number. This 

rulemaking creates new information 

collection requirements for phase-in 

reporting and record retention 

requirements. 

In compliance with the requirements 

of the PRA, NHTSA is separately 

publishing a document requesting 

comment on NHTSA’s intention to 

request approval for a new information 

collection request. Specifically, NHTSA 

is requesting approval for a new 

information collection that would 

require manufacturers of passenger cars 

and trucks and multipurpose passenger 

vehicles with a GVWR or 3,855 kg 

(8,500 lb) or less and buses with a 

GVWR of 4,536 kg (10,000 lb) or less to 

annually submit a report, and maintain 

records related to the report, concerning 

the number of such vehicles that meet 

the child restraint anchorage system 

requirements of FMVSS No. 225 during 

the phase-in of those requirements. 

The phase-in of the requirements 

would be completed approximately 6 

years after publication of the final rule. 

The purpose of the reporting 

requirements is to aid the agency in 

determining whether a manufacturer of 

passenger cars and trucks and 

multipurpose passenger vehicles with a 

GVWR of 3,855 kg (8,500 lb) or less, or 

buses with a GVWR of 4,536 kg (10,000 

lb) or less, has complied with the child 

restraint anchorage system requirements 

during the phase-in of those 

requirements. 

NHTSA estimates this collection will 

impact 22 manufacturers each year and 

will have a total annual burden of 

approximately 22 hours and $0 nonlabor costs. 

Unfunded Mandates Reform Act 

(UMRA) 

The Unfunded Mandates Reform Act 

of 1995 (UMRA) requires Federal 

agencies to prepare a written assessment 

of the costs, benefits, and other effects 

of proposed or final rules that include 

a Federal mandate likely to result in the 

expenditure by state, local, or tribal 


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governments, in the aggregate, or by the 

private sector, of more than $100 

million annually (adjusted annually for 

inflation, with base year of 1995). 

UMRA also requires an agency issuing 

an NPRM or final rule subject to the Act 

to select the ‘‘least costly, most costeffective or least burdensome alternative 

that achieves the objectives of the rule.’’ 

This final rule would not result in a 

Federal mandate that will likely result 

in the expenditure by state, local, or 

tribal governments, in the aggregate, or 

by the private sector, of more than $100 

million annually (adjusted annually for 

inflation, with base year of 1995). 

Executive Order 12988 (Civil Justice 

Reform) 

With respect to the review of the 

promulgation of a new regulation, 

section 3(b) of Executive Order 12988, 

‘‘Civil Justice Reform’’ (61 FR 4729, Feb. 

7, 1996), requires that Executive 

agencies make every reasonable effort to 

ensure that the regulation: (1) Clearly 

specifies the preemptive effect; (2) 

clearly specifies the effect on existing 

Federal law or regulation; (3) provides 

a clear legal standard for affected 

conduct, while promoting simplification 

and burden reduction; (4) clearly 

specifies the retroactive effect, if any; (5) 

adequately defines key terms; and (6) 

addresses other important issues 

affecting clarity and general 

draftsmanship under any guidelines 

issued by the Attorney General. This 

document is consistent with that 

requirement. 

Pursuant to this Order, NHTSA notes 

as follows. The issue of preemption is 

discussed above. NHTSA notes further 

that there is no requirement that 

individuals submit a petition for 

reconsideration or pursue other 

administrative proceedings before they 

may file suit in court. 

Congressional Review Act 

The Congressional Review Act, 5 

U.S.C. 801 et seq., as added by the Small 

Business Regulatory Enforcement 

Fairness Act of 1996, generally provides 

that before a rule may take effect, the 

agency promulgating the rule must 

submit a rule report, which includes a 

copy of the rule, to each House of the 

Congress and to the Comptroller General 

of the United States. NHTSA will 

submit a report containing this rule and 

other required information to the U.S. 

Senate, the U.S. House of 

Representatives, and the Comptroller 

General of the United States prior to 

publication of the rule in the Federal 

Register. This rule does not meet the 

criteria in 5 U.S.C. 804(2) to be 

considered a major rule. The rule will 

be effective sixty days after the date of 

publication in the Federal Register. 

National Technology Transfer and 

Advancement Act 

Under the National Technology 

Transfer and Advancement Act of 1995 

(NTTAA) (Pub. L. 104–113), all Federal 

agencies and departments shall use 

technical standards that are developed 

or adopted by voluntary consensus 

standards bodies, using such technical 

standards as a means to carry out policy 

objectives or activities determined by 

the agencies and departments. 

Voluntary consensus standards are 

technical standards (e.g., materials 

specifications, test methods, sampling 

procedures, and business practices) that 

are developed or adopted by voluntary 

consensus standards bodies, such as the 

International Organization for 

Standardization (ISO) and the Society of 

Automotive Engineers (SAE). The 

NTTAA directs this agency to provide 

Congress, through OMB, explanations 

when we decide not to use available and 

applicable voluntary consensus 

standards. There are no voluntary 

consensus standards developed by 

voluntary consensus standards bodies 

pertaining to this final rule. 

Plain Language Requirement 

Executive Order 12866 requires each 

agency to write all rules in plain 

language. Application of the principles 

of plain language includes consideration 

of the following questions: 

• Have we organized the material to 

suit the public’s needs? 

• Are the requirements in the rule 

clearly stated? 

• Does the rule contain technical 

language or jargon that isn’t clear? 

• Would a different format (grouping 

and order of sections, use of headings, 

paragraphing) make the rule easier to 

understand? 

• Would more (but shorter) sections 

be better? 

• Could we improve clarity by adding 

tables, lists, or diagrams? 

• What else could we do to make the 

rule easier to understand? 

NHTSA has considered these 

questions and attempted to use plain 

language in promulgating this final rule. 

If readers have suggestions on how we 

can improve our use of plain language, 

please write us. 

Regulatory Identifier Number (RIN) 

The DOT assigns a regulation 

identifier number (RIN) to each 

regulatory action listed in the Unified 

Agenda of Federal Regulations. The 

Regulatory Information Service Center 

publishes the Unified Agenda in April 

and October of each year. The RIN 

contained in the heading at the 

beginning of this document may be used 

to find this action in the Unified 

Agenda. 

Privacy Act 

In accordance with 5 U.S.C. 553(c), 

DOT solicits comments from the public 

to better inform its decision-making 

process. DOT posts these comments, 

without edit, including any personal 

information the commenter provides, to 

www.regulations.gov, as described in 

the system of records notice (DOT/ALL– 

14 FDMS), which can be reviewed at 

www.transportation.gov/privacy. 

Anyone can search the electronic form 

of all comments received into any of our 

dockets by the name of the individual 

submitting the comment (or signing the 

comment, if submitted on behalf of an 

association, business, labor union, etc.). 

You may review DOT’s complete 

Privacy Act Statement in the Federal 

Register published on April 11, 2000 

(Volume 65, Number 70; Pages 19477– 

78). 

Incorporation by Reference 

Updates to FMVSS No. 225 (49 CFR 

571.225) in this final rule include new 

requirements to evaluate the lower 

anchorage depth and clearance angle 

using new tools. NHTSA incorporates 

by reference two drawing packages, 

with detailed drawings of the tools used 

to measure these new requirements, into 

FMVSS No. 225 (49 CFR 571.225). The 

drawing packages are titled, Anchorage 

Depth Tool, dated April 2020, and 

Clearance Angle Tool, dated April 2020. 

Interested persons may use the drawing 

package to manufacture the standard 

seat assembly for their own use if they 

wish to do so. 

NHTSA has placed a copy of the 

material in the docket for this final rule. 

Interested persons can download a copy 

of the material or view the material 

online by accessing 

www.regulations.gov, phone 1–877– 

378–5457, or by contacting NHTSA’s 

Chief Counsel’s Office at the phone 

number and address set forth in the FOR

FURTHER INFORMATION CONTACT section of 

this document. The material is also 

available for inspection at the 

Department of Transportation, Docket 

Operations, Room W12–140, 1200 New 

Jersey Avenue SE, Washington, DC; 

phone: 202–366–9826. 


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Regulatory Text 

List of Subjects 

49 CFR Part 571 

Imports, Incorporation by Reference, 

Motor vehicle safety, Motor vehicles, 

Tires. 

49 CFR Part 585 

Reporting and recordkeeping 

requirements 

In consideration of the foregoing, 

NHTSA amends 49 CFR part 571 as set 

forth below. 

PART 571—FEDERAL MOTOR 

VEHICLE SAFETY STANDARDS 

■ 1. The authority citation for part 571 

continues to read as follows: 

Authority: 49 U.S.C. 322, 30111, 30115, 

30117 and 30166; delegation of authority at 

49 CFR 1.95. 

■ 2. Section 571.5 is amended by adding 

paragraphs (k)(10) and (11) to read as 

follows: 

§ 571.5 Matter incorporated by reference. 

* * * * * 

(k) * * * 

(10) Drawing Package, Anchorage 

Depth Tool, dated April 2020; approved 

for § 571.225. 

(11) Drawing Package, Clearance 

Angle Tool, dated April 2020; approved 

for § 571.225. 

* * * * * 

■ 3. Section 571.213b is amended by: 

■ a. Revising S5.5.2(j); 

■ b. Adding S5.6.1.13 and S5.6.1.14; 

■ c. Revising S5.9(a) through (c); and 

■ d. Adding figures 15 and 16. 

The revisions and additions read as 

follows: 

§ 571.213b Child restraint systems; 

Mandatory applicability beginning 

December 5, 2026. 

* * * * * 

S5.5.2 * * * 

(j) In the case of each child restraint 

system equipped with a tether strap the 

statement: Secure the tether strap 

provided with this child restraint. 

* * * * * 

S5.6.1.13 In the case of child 

restraint systems marked as specified in 

S5.9(a) and (b) of this standard, explain 

that the markings identify the lower 

anchor connectors and the tether anchor 

connector, respectively, and that the 

consumer should look for corresponding 

marks on the vehicle child restraint 

anchorage system to attach the 

appropriate connectors of the child 

restraint system. 

S5.6.1.14 Use the following terms 

when referring to the different 

components of the child restraint 

anchorage system or for components of 

the child restraint system that are used 

to connect the child restraint system to 

the vehicle: ‘‘lower anchor’’ means the 

lower anchorage of the child restraint 

anchorage system in the vehicle, ‘‘tether 

anchor’’ means the top tether anchorage 

of the child restraint anchorage system 

in the vehicle, ‘‘lower anchor 

attachment’’ means the child restraint 

system or the detachable base’s (in the 

case of a rear-facing child restraint with 

a detachable base) lower anchorage 

connector and the lower anchorage strap 

(for flexible lower anchorage 

attachments), ‘‘rigid lower anchor 

attachment’’ means the child restraint 

system or the detachable base’s (in the 

case of a rear-facing child restraint with 

a detachable base) lower anchorage 

connector that is rigidly attached to the 

CRS and does not have a lower 

anchorage strap, and ‘‘tether’’ means the 

child restraints system’s tether hook and 

tether strap. 

* * * * * 

S5.9 * * * 

(a) Each add-on child restraint system 

other than a car bed, harness, or beltpositioning seat shall have components 

permanently attached to the system that 

enable the restraint to be securely 

fastened to the lower anchorages of the 

child restraint anchorage system 

specified in Standard No. 225 

(§ 571.225) and depicted in NHTSA 

Standard Seat Assembly; FMVSS No. 

213, No. NHTSA–213–2021, (March 

2023) (incorporated by reference, see 

§ 571.5). The components must be 

attached to the add-on child restraint by 

use of a tool, such as a screwdriver. In 

the case of rear-facing child restraints 

with detachable bases, only the base is 

required to have the components. All 

components provided to attach the addon child restraint or the detachable base 

(in the case of a rear-facing child 

restraint with a detachable base) to the 

lower anchorages of the child restraint 

anchorage system shall be permanently 

marked with the pictogram in figure 15 

to this section. 

(b) In the case of each child restraint 

system that has components for 

attaching the system to a tether 

anchorage, those components shall 

include a tether hook that conforms to 

the configuration and geometry 

specified in figure 11 to this section. 

The tether hook or the tether strap shall 

be permanently marked with either 

pictogram shown in figure 16 to this 

section. If the mark is on the tether strap 

or on a tag attached to the tether strap, 

the mark must be located within 25 mm 

of the tether hardware assembly (which 

consists of a tether hook and a webbing 

tightening mechanism designed to 

tighten or loosen the tether strap). 

(c) In the case of each child restraint 

system that has components, including 

belt webbing, for attaching the system to 

an anchorage of a child restraint 

anchorage system (lower anchorage or 

tether anchorage), the belt webbing shall 

be adjustable so that the child restraint 

can be tightly attached to the vehicle. 

The length of the tether hardware 

assembly, which consists of a tether 

hook and a mechanism designed to 

tighten and loosen the tether strap, shall 

not exceed 165 mm. 

* * * * * 

Figure 15 to § 571.213b—Lower 

Anchorage Connector Symbol 


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Note 1 to Figure 15 to § 571.213b: 

Drawing not to scale. 

Note 2 to Figure 15 to § 571.213b: 

Symbol may be shown in mirror image. 

Note 3 to Figure 15 to § 571.213b: 

Color of the symbol is at the option of 

the manufacturer. 

Figure 16 to § 571.213b—Tether 

Anchorage Connector Symbols 

Note 1 to Figure 16 to § 571.213b: 

Drawing not to scale. 

Note 2 to Figure 16 to § 571.213b: 

Symbol may be shown in mirror image. 

Note 3 to Figure 16 to § 571.213b: 

Color of the symbol is at the option of 

the manufacturer. 

Note 4 to Figure 16 to § 571.213b: 

Either symbol may be marked at the 

option of the manufacturer. 

■ 4. Section 571.225 is amended by: 

■ a. Revising S4.2; 

■ b. Removing S4.3, S4.4, and S4.5; 

■ c. Redesignating S4.6 as S4.3 and 

revising it; 

■ d. Revising S5 and S6; 

■ e. Revising the first sentence of S8 

introductory text and revising S8.1 

introductory text; 

■ f. Removing and reserving S8.2; 

■ g. Revising S9 introductory text and 

S9.1.1(d) and S9.2; 

■ h. Adding S9.2.4 and S9.2.5; 

■ i. Revising S9.5; 

■ j. Revising S11, S12, and S13; 

■ k. Removing S14, S15, and S16; 

■ l. Revising figures 8, 9, 10, and 19, 

removing and reserving figure 11, andadding figures 23 through 28. 

The revisions and additions read as 

follows: 

§ 571.225 Child restraint anchorage 

systems. 

* * * * * 

S4.2 Vehicles shall be equipped as 

specified in paragraphs S4.2(a) through 

(c), except as provided in S5 of this 

standard. 

(a) Each vehicle with three or more 

forward-facing rear designated seating 

positions shall be equipped as specified 

in S4.2(a)(1) and (2). 

(1) Each vehicle shall be equipped 

with a child restraint anchorage system 

conforming to the requirements of S6 

and S9 of this standard at not fewer than 

two forward-facing rear designated 

seating positions. At least one of the 

child restraint anchorage systems shall 

be installed at a forward-facing seating 

position in the second row in each 

vehicle that has three or more rows, if 

such a forward-facing seating position is 

available in that row. 

(2) Each vehicle shall be equipped 

with a tether anchorage conforming to 

the requirements of S6 of this standard 

at a third forward-facing rear designated 

seating position. The tether anchorage of 

a child restraint anchorage system may 

count towards the third required tether 

anchorage. In each vehicle with a 

forward-facing rear designated seating 

position other than an outboard 

designated seating position, at least one 

tether anchorage (with or without the 

lower anchorages of a child restraint 

anchorage system) shall be at such a 

designated seating position. 

(b) Each vehicle with not more than 

two forward-facing rear designated 

seating positions shall be equipped with 

a child restraint anchorage system 

conforming to the requirements of S6 

and S9 of this standard at each forwardfacing rear designated seating position. 

(c) Each vehicle without any forwardfacing rear designated seating position 

shall be equipped with a tether 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1343 

anchorage conforming to the 

requirements of S6 of this standard at 

each forward-facing front passenger 

designated seating position. 

S4.3 Movable seats. (a) A vehicle 

that is equipped with a forward-facing 

rear designated seating position that can 

be moved such that it is capable of being 

used at either an outboard or nonoutboard forward-facing designated 

seating position shall be considered as 

having a forward-facing non-outboard 

designated seating position. Such a 

movable seat must be equipped with a 

tether anchorage that meets the 

requirements of S6 of this standard or a 

child restraint anchorage system that 

meets the requirements of S6 and S9 of 

this standard, if the vehicle does not 

have another forward-facing nonoutboard designated seating position 

that is so equipped. 

(b) Tether and lower anchorages shall 

be available for use at all times, except 

when the seating position for which it 

is installed is not available for use 

because the vehicle seat has been 

removed or converted to an alternate 

use such as allowing for the carrying of 

cargo. 

S5 General exceptions. Vehicles 

manufactured before September 1, 2031, 

must meet the requirements of S5.1. 

Vehicles manufactured on or after 

September 1, 2031, must meet the 

requirements of S5.2. 

S5.1 Vehicles manufactured before 

September 1, 2031. (a) Convertibles and 

school buses are excluded from the 

requirements to be equipped with tether 

anchorages. 

(b) A vehicle may be equipped with 

a built-in child restraint system 

conforming to the requirements of 

Standard No. 213 (§ 571.213) or 

Standard No. 213b (§ 571.213b) as 

applicable, instead of one of the 

required tether anchorages or child 

restraint anchorage systems. 

(c) Vehicles with no air bag in front 

passenger designated position: 

(1) Each vehicle that does not have a 

rear designated seating position and 

does not have an air bag installed at 

front passenger designated seating 

positions pursuant to a temporary 

exemption granted by NHTSA under 49 

CFR part 555, must have a child 

restraint anchorage system installed at a 

front passenger designated seating 

position. In the case of convertibles, the 

front designated passenger seating 

position need have only the two lower 

anchorages meeting the requirements of 

S9 of this standard. 

(2) Each vehicle that has a rear 

designated seating position and meets 

the conditions in S4.5.4.1(b) of Standard 

No. 208 (§ 571.208), and does not have 

an air bag installed at front passenger 

designated seating positions pursuant to 

a temporary exemption granted by 

NHTSA under 49 CFR part 555, must 

have a child restraint anchorage system 

installed at a front passenger designated 

seating position in place of one of the 

child restraint anchorage systems that is 

required for the rear seat. In the case of 

convertibles, the front designated 

passenger seating position need have 

only the two lower anchorages meeting 

the requirements of S9 of this standard. 

(d) A vehicle that does not have an air 

bag on-off switch meeting the 

requirements of S4.5.4 of Standard No. 

208 (§ 571.208) shall not have any child 

restraint anchorage system installed at a 

front designated seating position. 

(e) A vehicle with a rear designated 

seating position for which interference 

with transmission and/or suspension 

components prevents the location of the 

lower bars of a child restraint anchorage 

system anywhere within the zone 

described by S9.2 of this standard is 

excluded from the requirement to 

provide a child restraint anchorage 

system at that position. However, except 

as provided elsewhere in this S5, such 

a vehicle must have a tether anchorage 

at a front passenger designated seating 

position. 

S5.2 Vehicles manufactured on or 

after September 1, 2031. (a) School 

buses are excluded from the 

requirements to be equipped with tether 

anchorages. 

(b) A vehicle may be equipped with 

a built-in child restraint system 

conforming to the requirements of 

Standard No. 213b (§ 571.213b) instead 

of one of the required tether anchorages 

or child restraint anchorage systems. 

(c) Vehicles with no air bag in front 

passenger designated position: 

(1) Each vehicle that does not have a 

rear designated seating position and 

does not have an air bag installed at 

front passenger designated seating 

positions pursuant to a temporary 

exemption granted by NHTSA under 49 

CFR part 555 must have a child restraint 

anchorage system installed at a front 

passenger designated seating position. 

(2) Each vehicle that has a rear 

designated seating position and meets 

the conditions in S4.5.4.1(b) of Standard 

No. 208 (§ 571.208), and does not have 

an air bag installed at front passenger 

designated seating positions pursuant to 

a temporary exemption granted by 

NHTSA under 49 CFR part 555, must 

have a child restraint anchorage system 

installed at a front passenger designated 

seating position in place of one of the 

child restraint anchorage systems that is 

required for the rear seat. 

(d) A vehicle that does not have an air 

bag on-off switch meeting the 

requirements of S4.5.4 of Standard No. 

208 (§ 571.208), shall not have any child 

restraint anchorage system installed at a 

front designated seating position. 

S6. Requirements for tether 

anchorages. Vehicles subject to 

Standard No. 225 (this section) shall 

meet the tether anchorage requirements 

specified in S6.1, S6.2, and S6.4 

according to the phase-in schedule 

specified in S13 of this standard. 

S6.1 Configuration of the tether 

anchorage. 

S6.1.1 Each tether anchorage shall: 

(a) Permit the attachment of a tether 

hook of a child restraint system meeting 

the configuration and geometry 

specified in figure 11 of Standard No. 

213 (figure 11 to § 571.213); 

(b) Be accessible without the need for 

any tools other than a screwdriver or 

coin; 

(c) Once accessed, be ready for use 

without the need for any tools; and 

(d) Be sealed to prevent the entry of 

exhaust fumes into the passenger 

compartment. 

S6.1.2 Each tether anchorage shall: 

(a) Consist of a rigid bar of any crosssection shape that permits the 

attachment of a tether hook (of a child 

restraint system) meeting the 

configuration and geometry specified in 

figure 11 of Standard No. 213 (figure 11 

to § 571.213), except in buses with a 

GVWR less than or equal to 10,000 

pounds and vehicles that use a routing 

device per S6.2.1.2; 

(b) Be accessible without the need for 

any tools and without folding the seat 

back (other than the head restraint) or 

removing carpet or other vehicle 

components (other than cargo covers) to 

access the anchorages. Individual tether 

anchorages may be covered with a cap, 

flap, or cover, provided that any cap, 

flap, or, cover is specifically designed to 

be opened, moved aside, or to otherwise 

give unobstructed access to the 

anchorage and is labeled with the 

symbol shown in figure 25 to this 

section; 

(c) Once accessed, be ready for use 

without the need for any tools; and 

(d) Be sealed to prevent the entry of 

exhaust fumes into the passenger 

compartment. 

S6.2 Location of the tether 

anchorage. 

S6.2.1 Subject to S6.2.1.2, the part of 

each tether anchorage that attaches to a 

tether hook must be located within the 

shaded zone shown in figures 3 through 

7 to this section of the designated 

seating position for which it is installed. 

The zone is defined with reference to 

the seating reference point (see § 571.3). 


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(For purposes of the figures, ‘‘H Point’’ 

is defined to mean seating reference 

point.) A tether anchorage may be 

recessed in the seat back, provided that 

it is not in the strap wrap-around area 

at the top of the vehicle seat back. For 

the area under the vehicle seat, the 

forwardmost edge of the shaded zone is 

defined by the torso line reference 

plane. 

S6.2.1.1 [Reserved] 

S6.2.1.2 In the case of a vehicle 

that— 

(a) Has a user-ready tether anchorage 

for which no part of the shaded zone 

shown in Figures 3 to 7 of this standard 

of the designated seating position for 

which the anchorage is installed is 

accessible without removing a seating 

component of the vehicle; and 

(b) Has a tether strap routing device 

that is— 

(1) Not less than 65 mm behind the 

torso line for that seating position, in 

the case of a flexible routing device or 

a deployable routing device, measured 

horizontally and in a vertical 

longitudinal plane; or 

(2) Not less than 100 mm behind the 

torso line for that seating position, in 

the case of a fixed rigid routing device, 

measured horizontally and in a vertical 

longitudinal plane, the part of that 

anchorage that attaches to a tether hook 

may, at the manufacturer’s option (with 

said option selected prior to, or at the 

time of, certification of the vehicle) be 

located outside that zone. 

(c) The measurement of the location 

of the flexible or deployable routing 

device described in S6.2.1.2(b)(1) is 

made with SFAD 2 properly attached to 

the lower anchorages. A 40 mm wide 

nylon tether strap is routed through the 

routing device and attached to the tether 

anchorage in accordance with the 

written instructions required by S12 of 

this standard. The forwardmost contact 

point between the strap and the routing 

device must be within the stated limit 

when the tether strap is flat against the 

top surface of the SFAD and tensioned 

to 55 to 65 N. In seating positions 

without lower anchorages of a child 

restraint anchorage system, the SFAD 2 

is held with its central lateral plane in 

the central vertical longitudinal plane of 

the seating position. The adjustable 

anchor attaching bars of the SFAD 2 are 

replaced by spacers that end flush with 

the back surface of the SFAD. 

S6.2.2 Subject to S6.2.2.2, the part of 

each tether anchorage to which a tether 

hook attaches must be located within 

the shaded zone shown in figures 3 

through 7 to this section of the 

designated seating position for which it 

is installed. The zone is defined with 

reference to the seating reference point 

(see § 571.3). (For purposes of the 

figures, ‘‘H Point’’ means seating 

reference point.) A tether anchorage 

may be recessed in the seat back, 

provided that it is not in the strap wraparound area at the top of the vehicle seat 

back. For the area under the vehicle 

seat, the forwardmost edge of the 

shaded zone is defined by a vertical 

plane 120 mm rearward of the ‘‘H 

Point,’’ as shown in figure 3 to this 

section. 

S6.2.2.1 Subject to S6.2.2.2, for 

vehicles with adjustable or removable 

head restraints or no head restraints, the 

tether anchorage to which a tether hook 

attaches must be located outside the 

zone created by a 325 mm radius sphere 

with its center on the R-point and 

truncated horizontally at 230 mm below 

the sphere’s center as shown in figures 

8 and 9 to this section. 

S6.2.2.2 In the case of a vehicle 

that— 

(a) Has a user-ready tether anchorage 

for which no part of the shaded zone 

shown in figures 4 through 7 and 10 to 

this section of the designated seating 

position for which the anchorage is 

installed is accessible without the need 

for folding the seatback (other than the 

head restraint) or removing a seating 

component of the vehicle; and 

(b) Has a tether strap routing device 

that is— 

(1) Not less than 65 mm behind the 

torso line for that seating position, in 

the case of a flexible routing device or 

a deployable routing device, measured 

horizontally and in a vertical 

longitudinal plane; or 

(2) Not less than 100 mm behind the 

torso line for that seating position, in 

the case of a fixed rigid routing device, 

measured horizontally and in a vertical 

longitudinal plane, the part of that 

anchorage that attaches to a tether hook 

may, at the manufacturer’s option (with 

said option selected prior to, or at the 

time of, certification of the vehicle) be 

located outside that zone. 

(c) The measurement of the location 

of the flexible or deployable routing 

device described in S6.2.2.2(b)(1) is 

made with SFAD 2 properly attached to 

the lower anchorages. A 40 mm wide 

nylon tether strap is routed through the 

routing device and attached to the tether 

anchorage in accordance with the 

written instructions required by S12 of 

this standard. The forwardmost contact 

point between the strap and the routing 

device must be within the stated limit 

when the tether strap is flat against the 

top surface of the SFAD and tensioned 

to 55 to 65 N. In seating positions 

without lower anchorages of a child 

restraint anchorage system, the SFAD 2 

is held with its central lateral plane in 

the central vertical longitudinal plane of 

the seating position. The adjustable 

anchorage attaching bars of the SFAD 2 

are replaced by spacers that end flush 

with the back surface of the SFAD 2. 

S6.3 Strength requirements for 

tether anchorages. (a) When tested in 

accordance with S8, the tether 

anchorage must not separate completely 

from the vehicle seat or seat anchorage 

or the structure of the vehicle. 

(b) Provisions for simultaneous and 

sequential testing: 

(1) In the case of vehicle seat 

assemblies equipped with more than 

one tether anchorage, the force referred 

to in this S6.3 may, at the agency’s 

option, be applied simultaneously to 

each of those tether anchorages. 

However, that force may not be applied 

simultaneously to tether anchorages for 

any two adjacent seating positions 

whose midpoints are less than 400 mm 

apart, as measured in accordance with 

S6.3(b)(i) and (ii) and figure 20 to this 

section. 

(i) The midpoint of the seating 

position lies in the vertical longitudinal 

plane that is equidistant from vertical 

longitudinal planes through the 

geometric center of each of the two 

lower anchorages at the seating position. 

For those seating positions that do not 

provide lower anchorages, the midpoint 

of the seating position lies in the 

vertical longitudinal plane that passes 

through the SgRP of the seating 

position. 

(ii) Measure the distance between the 

vertical longitudinal planes passing 

through the midpoints of the adjacent 

seating positions, as measured along a 

line perpendicular to the planes. 

(2) A tether anchorage of a particular 

child restraint anchorage system will 

not be tested with the lower anchorages 

of that anchorage system if one or both 

of those lower anchorages have been 

previously tested under this standard. 

S6.4 Marking and conspicuity 

requirements for tether anchorages. 

Vehicles subject to Standard No. 225 

(this section) shall meet S6.4 according 

to the phase-in schedule specified in 

S13 of this standard. 

(a) For each tether anchorage installed 

pursuant to S4 of this standard, there 

shall be a permanent marking that: 

(1) Consists of one of the pictograms 

shown in figure 25 to this section that 

is not less than 20 mm in height; 

(2) Except for vehicles that use a 

routing device per S6.2.2.2, the center of 

the pictogram in the longitudinal 

direction must be in the vertical 

longitudinal plane that passes through 

the center of the tether anchorage bar (± 

half of the tether anchorage length), as 

shown in figure 26 (Left) to this section; 


ddrumheller on DSK120RN23PROD with RULES3
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1345 

or the center of the pictogram in the 

lateral direction must be in the 

horizontal lateral plane that passes 

through the center of the tether 

anchorage bar (± half of the pictogram 

height), as shown in figure 26 (right) to 

this section. 

(3) The nearest edge of the marking 

shall be located not more than 100 mm 

away from the tether anchorage bar as 

shown in figure 27 to this section. No 

other attachment feature to secure 

occupant items (i.e., cargo hooks or 

similar) shall be nearer to the marking 

than the distance from the marking to 

the tether anchorage. Vehicles with 

routing devices per S6.2.2.2 may use 

tags attached to the routing device. 

(b) The tether anchorage bar may be 

covered by a cap or cover that is 

removable without the use of any tool, 

provided that the cap or cover is 

permanently labeled with a marking 

meeting the requirements of S6.4(a)(1). 

If the cap or cover is permanently 

attached to the vehicle, the tether 

anchorage is not required to be 

separately marked. If the cap or cover is 

not permanently attached to the vehicle, 

the tether anchorage must also be 

marked with the symbol meeting 

S6.4(a)(1) through (3). 

(c) For vehicles that have a cargo 

cover that needs to be moved or 

removed to access the tether anchorages, 

the cargo cover must be permanently 

marked with the symbol meeting 

S6.4.1(a)(1) of this standard for each 

tether anchorage that is accessible under 

the cargo cover. Tether anchorages 

under the cargo cover must also be 

marked per S6.4(a). 

* * * * * 

S8 Test procedures. Each vehicle 

shall meet the requirements of S6.3 

when tested according to the following 

procedures. * * * 

S8.1 Apply the force specified in 

S6.3 as follows— 

* * * * * 

S9. Requirements for the lower 

anchorages of the child restraint 

anchorage system. Vehicles subject to 

Standard No. 225 (this section) shall 

meet the lower anchorage requirements 

specified in S9.2 and S9.5 according to 

the phase-in schedule specified in S13 

of this standard. 

S9.1 Configuration of the lower 

anchorages 

S9.1.1 * * * 

(d) The bars must not be capable of 

being stowable or foldable. 

* * * * * 

S9.2 Location of the lower 

anchorages. 

* * * * * 

S9.2.4 The lower anchorages shall 

be located such that the lower 

anchorage depth tool depicted in 

Drawing Package, Anchorage Depth 

Tool, dated April 2020 (incorporated by 

reference; see § 571.5), measures an 

anchorage depth of 25 mm or less using 

the procedure in S11(c) of this standard. 

S9.2.5 The lower anchorages shall 

be located such that the tool depicted in 

Drawing Package, Clearance Angle Tool, 

dated April 2020 (incorporated by 

reference; see § 571.5), measures a 

clearance angle of at least 54 degrees 

using the procedure in S11(b) of this 

standard. 

* * * * * 

S9.5 Marking and conspicuity 

requirements. 

S9.5.1 Requirements for lower 

anchors. Lower anchorages must meet 

the requirements in S9.5.1(a) or (b). 

(a) For each bar installed pursuant to 

S4, the vehicle shall be permanently 

marked with a circle: 

(1) That is not less than 13 mm in 

diameter; 

(2) That is either solid or open, with 

or without words, symbols, or 

pictograms, provided that if words, 

symbols or pictograms are used, their 

meaning is explained to the consumer 

in writing, such as in the vehicle’s 

owner’s manual; and 

(3) That is located such that its center 

is on each seat back between 50 and 100 

mm above or on the seat cushion 100 

±25 mm forward of the intersection of 

the vertical transverse and horizontal 

longitudinal planes intersecting at the 

horizontal centerline of each lower 

anchorage, as illustrated in figure 22 to 

this section. The center of the circle 

must be in the vertical longitudinal 

plane that passes through the center of 

the bar (±25 mm). 

(4) The circle may be on a tag. 

(b) The vehicle shall be configured 

such that the following is visible: Each 

of the bars installed pursuant to S4, or 

a permanently attached guide device for 

each bar. The bar or guide device must 

be visible without the compression of 

the seat cushion or seat back, when the 

bar or device is viewed, in a vertical 

longitudinal plane passing through the 

center of the bar or guide device, along 

a line making an upward 30-degree 

angle with a horizontal plane. Seat 

backs are in the nominal design riding 

position. The bars may be covered by a 

removable cap or cover, provided that 

the cap or cover is permanently marked 

with words, symbols or pictograms 

whose meaning is explained to the 

consumer in written form as part of the 

owner’s manual. 

S9.5.2 Requirements for lower 

anchors. Lower anchorages must meet 

the requirements in S9.5.2(a) and (b), as 

applicable. 

(a) For each bar installed pursuant to 

S4, the vehicle shall be permanently 

marked with a symbol that: 

(1) Is not less than 13 mm in diameter; 

(2) Contains the pictogram shown in 

figure 24 to this section; and 

(3) Is located such that its center is on 

each seat back between 50 and 100 mm 

above or on the seat cushion between 

100 to ¥50 mm forward of the 

intersection of the vertical transverse 

and horizontal longitudinal planes 

intersecting at the horizontal centerline 

of each lower anchorage, as illustrated 

in figure 19 to this section. The center 

of the symbol must be in the vertical 

longitudinal plane that passes through 

the center of the bar (±25 mm). 

(4) The symbol may be on a tag. 

(b) The bars may be covered by a 

removable cap or cover, provided that 

the cap or cover is permanently marked 

with the pictogram shown in figure 24 

to this section. If the cap or cover is 

permanently attached to the vehicle, the 

lower anchorage bars are not required to 

be separately marked with the 

pictogram. If the cap or cover is not 

permanently attached to the vehicle, the 

lower anchorage bars must also be 

marked with the symbol meeting 

S9.5.2(a)(1) through (4). 

* * * * * 

S11. Test procedures. Each vehicle 

shall meet the requirements of this 

standard when tested according to the 

following procedures. Where a range of 

values is specified, the vehicle shall be 

able to meet the requirements at all 

points within the range. 

(a) Strength requirements—(1) 

Forward force direction. Place SFAD 2 

in the vehicle seating position and 

attach it to the two lower anchorages of 

the child restraint anchorage system. Do 

not attach the tether anchorage. A 

rearward horizontal force of 135 ±15 N 

is applied to the center of the lower 

front crossbar of SFAD 2 to press the 

device against the seat back as the foreaft position of the rearward extensions 

of the SFAD is adjusted to remove any 

slack or tension. Apply a preload force 

of 500 N horizontally and in the vertical 

centerline of the SFAD 2 at point X. 

Increase the pull force as linearly as 

practicable to a full force application of 

11,000 N in not less than 24 seconds 

and not more than 30 seconds and 

maintain at an 11,000 N level for 1 

second. 

(2) Lateral force direction. Place SFAD 

2 in the vehicle seating position and 

attach it to the two lower anchorages of 

the child restraint anchorage system. Do 

not attach the tether anchorage. A 


ddrumheller on DSK120RN23PROD with RULES3
1346 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

rearward force of 135 ±15 N is applied 

to the center of the lower front crossbar 

of SFAD 2 to press the device against 

the seat back as the fore-aft position of 

the rearward extensions of the SFAD is 

adjusted to remove any slack or tension. 

Apply a preload force of 500 N 

horizontal and perpendicular to the 

longitudinal centerline of the SFAD 2 at 

point X of the test device. Increase the 

pull force as linearly as practicable to a 

full force application of 5,000 N in not 

less than 24 seconds and not more than 

30 seconds and maintain at a 5,000 N 

level for 1 second. 

(b) Clearance angle. The seat back 

angle, if adjustable, is set at the 

manufacturer’s nominal design seat 

back angle. If the position is not 

specified, set the seat back at the first 

detent rearward of 25° from the vertical. 

Remove or open any lower anchorage 

cover, if present, to expose the lower 

anchorage. To measure clearance angle, 

attach the clearance angle tool to the 

lower anchorage and apply a vertical 

force of 67 N (15 lbf) to the tool. 

Measure the angle (with respect to the 

horizontal) of the tool while the force is 

being applied. 

(c) Anchorage depth. The seat back 

angle, if adjustable, is set at the 

manufacturer’s nominal design seat 

back angle. If the position is not 

specified, set the seat back at the first 

detent rearward of 25° from the vertical. 

To measure the anchorage depth, 

subtract 30 degrees from the measured 

seat pan angle to calculate the view 

angle. With the anchorage depth tool 

(see figure 28 to this section) on a flat 

surface, adjust the view bar to read the 

view angle. Slide the zeroing strip along 

the view bar so that it is barely touching 

the top of the depth tool hook. Move the 

view bar forward, so the end of the 

zeroing strip is aligned with the zeroscribe line. For hidden anchorages, slide 

the anchorage depth tool so that it reads 

0 mm at the rear edge of the slider. For 

visible anchorages, align the depth 

gauge to 25 mm so that negative values 

can be read. Attach the depth tool 

centered to the lower anchorage. Adjust 

the depth tool base to be within ±2 

degrees of the view angle (30 degrees 

minus seat pan angle) to set the toolparallel to the seat pan angle. Move the 

entire slider bar forward until the 

zeroing strip contacts the vehicle seat 

back or any other vehicle part. 

S12. Written instructions. Vehicles 

subject to Standard No. 225 (this 

section) shall meet the written 

instruction requirements specified in 

either S12.1 or S12.2 according to the 

phase-in schedule specified in S13. 

S12.1 Written instructions shall: 

(a) Indicate which seating positions in 

the vehicle are equipped with tether 

anchorages and child restraint 

anchorage systems; 

(b) In the case of vehicles required to 

be marked as specified in paragraphs 

S4.1 and S9.5 of this standard, explain 

the meaning of markings provided to 

locate the lower anchorages of child 

restraint anchorage systems; and 

(c) Include instructions that provide a 

step-by-step procedure, including 

diagrams, for properly attaching a child 

restraint system’s tether strap to the 

tether anchorages. 

S12.2 Written instructions shall: 

(a) Indicate which seating positions in 

the vehicle are equipped with tether 

anchorages and child restraint 

anchorage systems; 

(b) In the case of vehicles required to 

be marked as specified in paragraphs 

S4.1 and S9.5 of this standard, explain 

the meaning of markings provided to 

locate the lower anchorages of child 

restraint anchorage systems and the top 

tether anchorages; 

(c) Include instructions that provide a 

step-by-step procedure, including 

diagrams, for properly attaching a child 

restraint system’s tether strap to the 

tether anchorages; 

(d) Include instructions on how to 

locate and access the tether anchorage 

and the lower anchorages; and 

(e) Use the following terms when 

referring to the different components of 

the child restraint anchorage system that 

are used to connect the child restraint 

system to the vehicle: ‘‘lower anchor’’ 

means the lower anchorage of the child 

restraint anchorage system in the 

vehicle, ‘‘tether anchor’’ means the top 

tether anchorage of the child restraint 

anchorage system in the vehicle, ‘‘lower 

anchor attachment’’ means the child 

restraint system or the detachable base’s 

(in the case of a rear-facing child 

restraint with a detachable base) lower 

anchorage connector and the lower 

anchorage strap (for flexible lower 

anchorage attachments), ‘‘rigid lower 

anchor attachment’’ means the child 

restraint system or the detachable base’s 

(in the case of a rear-facing child 

restraint with a detachable base) lower 

anchorage connector that is rigidly 

attached to the CRS or detachable base, 

respectively, and does not have a lower 

anchorage strap, and ‘‘tether’’ means the 

child restraints system’s tether hook and 

tether strap. 

S13 Phase-in schedule. The S13 

phase in schedule details when listed 

requirements become inactive and are 

replaced by newer requirements. 

Requirements in Standard No. 225 (this 

section) not listed in S13 shall be in 

effect before, during, and after the S13 

phase-in. 

S13.1 Vehicle certification 

information. At any time during the 

production years ending August 31, 

2029, and August 31, 2030, each 

manufacturer shall, upon request from 

the Office of Vehicle Safety Compliance, 

provide information identifying the 

vehicles (by make, model and vehicle 

identification number) that have been 

certified as complying with the child 

restraint anchorage usability 

requirements of this standard. 

Manufacturers shall specify the number 

of vehicles meeting each phase-in 

percentage. The manufacturer’s 

designation of a vehicle as a certified 

vehicle is irrevocable. 

S13.1.1 Pre phase-in. Vehicles 

manufactured before September 1, 2028, 

are subject to S6.1.1, S6.2.1, S9.2.1, 

S9.2.2, S9.2.3, S9.5.1, and S12.1 of this 

standard. 

S13.1.2 Phase-in year 1. Vehicles 

manufactured on or after September 1, 

2028, and before September 1, 2029. 

The total number of individual vehicles 

complying with S6.1.2, S6.2.2, S6.4, 

S9.2 (except for S9.2.2(a)), S9.5.2, and 

S12.2 of this standard shall be not less 

than 20 percent of a vehicle 

manufacturer’s total production for this 

time period. The remaining 80 percent 

of a vehicle manufacturer’s total 

production are subject to S6.1.1, S6.2.1, 

S9.2.1, S9.2.2, S9.2.3, S9.5.1, and S12.1 

of this standard. 

S13.1.3 Phase-in year 2. Vehicles 

manufactured on or after September 1, 

2029, and before September 1, 2030. 

The total number of individual vehicles 

complying with S6.1.2, S6.2.2, S6.4, 

S9.2 (except for S9.2.2(a)), S9.5.2, and 

S12.2 of this standard shall be not less 

than 50 percent of a vehicle 

manufacturer’s total production for this 

time period. The remaining 50 percent 

of a vehicle manufacturer’s total 

production are subject to S6.1.1, S6.2.1, 

S9.2.1, S9.2.2, S9.2.3, S9.5.1, and S12.1 

of this standard. 

S13.1.4 Phase-in year 3 and beyond. 

Vehicles manufactured on or after 

September 1, 2030. The total number of 

vehicles complying with S6.1.2, S6.2.2, 

S6.4, S9.2 (except for S9.2.2(a)), S9.5.2, 

and S12.2 shall be not less than 100 

percent of a vehicle manufacturer’s total 

production. 

S13.2 Vehicles produced by more 

than one manufacturer. 

S13.2.1 For the purpose of 

calculating average annual production 

of vehicles for each manufacturer and 

the number of vehicles manufactured by 

each manufacturer under S13.1.1 

through S13.1.4, a vehicle produced by 

more than one manufacturer shall be 


ddrumheller on DSK120RN23PROD with RULES3
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1347 

attributed to a single manufacturer as 

follows: 

(a) A vehicle which is imported shall 

be attributed to the importer. 

(b) A vehicle manufactured in the 

United States by more than one 

manufacturer, one of which also 

markets the vehicle, shall be attributed 

to the manufacturer which markets the 

vehicle. 

S13.2.2 A vehicle produced by more 

than one manufacturer shall be 

attributed to any one of the vehicle’s 

manufacturers specified by an express 

written contract, reported to the 

National Highway Traffic Safety 

Administration under 49 CFR part 585, 

between the manufacturers so specified 

and the manufacturer to which the 

vehicle would otherwise be attributed 

under S13.2.1. 

BILLING CODE 4910–59–P 

Figures to § 571.225 

* * * * * 

Figure 8 to § 571.225. Side View of 325 

mm Radius Sphere Zone From R-Point, 

Truncated at 230 mm Below the Center 

Figure 9 to § 571.225. ThreeDimensional 325 mm Radius Sphere 

Zone From R-Point, Truncated Along 

the Lower Edge at 230 mm Below Its 

Center 


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A.ME~ 
1348 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

Figure 10 to § 571.225—Side View. User 

Ready Tether Anchorage Location 


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Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1349 

Figure 11 to § 571.225. [Reserved] 

* * * * * 

Figure 19 to § 571.225. Placement of 

Symbol on the Seat Back and Seat 

Cushion of Vehicle 

* * * * * Figure 23 to § 571.225. Clearance Angle 

Tool 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.043</GPH>

Notes: 

I. Drawing not to scale. 

2. 50 mm :Sa :S 100 mm. 

3. 100 mm :Sb :S-50 mm. 

Horizontal Longitmlinal Plane 

Vertical Transverse Plane 

Horizontal Center Line of Each Bae of the 

Lower Universal Anchorage System 
1350 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

Figure 24 to § 571.225—Lower 

Anchorage Symbol 

Note 1 to Figure 24 to § 571.225: 

Drawing not to scale. 

Note 2 to Figure 24 to § 71.225: 

Symbol may be shown in mirror image. 

Note 3 to Figure 24 to § 571.225: Color 

of the symbol at the option of the 

manufacturer. 

Figure 25 to § 571.225. Tether 

Anchorage Symbols 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.044</GPH> ER07JA25.045</GPH>

13mm 

Minimum 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1351 

Note 1 to Figure 25 to § 571.225: 

Drawing not to scale. 

Note 2 to Figure 25 to § 571.225: 

Symbol may be shown in mirror image. 

Note 3 to Figure 25 to § 571.225: Color 

of the symbol at the option of the 

manufacturer. 

Figure 26 to § 571.225. Tether 

Anchorage Marking Location— 

Alignment (No Cover) 

Note 1 to Figure 26 to § 571.225: 

(Tolerance of ± half of the anchorage 

length)/(Tolerance of ± half of the 

pictogram height). 

Figure 27 to § 571.225. Tether 

Anchorage Marking Location—Distance 

(No Cover) 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.046</GPH> ER07JA25.047</GPH> ER07JA25.048</GPH>

• • j, 

LEFT 

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anchorage length 

RIGHT 

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anchorage 

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tether 

symbol 

'\_ Tether Allcltorage 

Distance from 

marld111to 

tether anchorap 

upto100mm 

'tether Anchorap 
1352 Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 

Figure 28 to § 571.225. Anchorage 

Depth Tool 

BILLING CODE 4910–59–C 

PART 585—PHASE-IN REPORTING 

REQUIREMENTS 

■ 5. The authority citation for part 585 

continues to read as follows: 

Authority: 49 U.S.C. 322, 30111, 30115, 

30117, and 30166; delegation of authority at 

49 CFR 1.95. 

■ 6. Add subpart O to read as follows: 

Subpart O—Child Restraint Anchorage 

Systems Phase-In Reporting Requirements 

Sec. 

585.135 Scope. 

585.136 Purpose. 

585.137 Applicability. 

585.138 Definitions. 

585.139 Response to inquiries. 

585.140 Reporting requirements. 

585.141 Records. 

Subpart O—Child Restraint Anchorage 

Systems Phase-In Reporting 

Requirements 

§ 585.135 Scope. 

This subpart establishes requirements 

for manufacturers of passenger cars, and 

of trucks and multipurpose passenger 

vehicles with a gross vehicle weight 

rating (GVWR) of 3,855 kilograms (8,500 

pounds) or less, and of buses with a 

GVWR of 4,536 kg (10,000 lb) or less, to 

submit a report per § 585.140, and 

maintain records related to the report 

according to § 585.141, concerning the 

number of such vehicles that meet the 

requirements of Standard No. 225, Child 

restraint anchorage systems (49 CFR 

571.225). 

§ 585.136 Purpose. 

The purpose of these reporting 

requirements is to assist the National 

Highway Traffic Safety Administration 

in determining whether a manufacturer 

has complied with Standard No. 225 (49 

CFR 571.225). 

§ 585.137 Applicability. 

This subpart applies to manufacturers 

of passenger cars, and of trucks and 

multipurpose passenger vehicles with a 

gross vehicle weight rating (GVWR) of 

3,855 kilograms (8,500 pounds) or less, 

and of buses with a GVWR of 4536 kg 

(10,000 lb) or less, for which Standard 

No. 225 (49 CFR 571.225) applies. 

However, this subpart does not apply to 

vehicles excluded by S5 of Standard No. 

225 from the requirements of that 

standard. 

§ 585.138 Definitions. 

(a) All terms defined in 49 U.S.C. 

30102 are used in their statutory 

meaning. 

(b) Bus, gross vehicle weight rating or 

GVWR, multipurpose passenger vehicle, 

passenger car, and truck are used as 

defined in 49 CFR 571.3. 

(c) Production year means the 12- 

month period between September 1 of 

one year and August 31 of the following 

year, inclusive. 

§ 585.139 Response to inquiries. 

At any time during the production 

years ending August 31, 2029, and 

August 31, 2030, each manufacturer 

shall, upon request from the Office of 

Vehicle Safety Compliance, provide 

information identifying the vehicles (by 

make, model and vehicle identification 

number) that have been certified as 

complying with Standard No. 225 (49 

CFR 571.225). The manufacturer’s 

designation of a vehicle as a certified 

vehicle is irrevocable. 

§ 585.140 Reporting requirements. 

(a) General reporting requirements. 

Within 60 days after the end of the 

production years ending August 31, 

2029, and August 31, 2030, each 

manufacturer shall submit a report to 

the National Highway Traffic Safety 

Administration concerning its 

compliance with the child restraint 

anchorage system requirements of 

Standard No. 225 (49 CFR 571.225) for 

applicable vehicles produced in that 

year. Each report shall: 

(1) Identify the manufacturer; 

(2) State the full name, title, and 

address of the official responsible for 

preparing the report; 

(3) Identify the production year being 

reported on; 

(4) Contain a statement regarding 

whether or not the manufacturer 

complied with the child restraint 

anchorage system requirements of 

Standard No. 225 (49 CFR 571.225) for 

the period covered by the report and the 

basis for that statement; 

(5) Provide the information specified 

in paragraph (b) of this section; 

(6) Be written in the English language; 

and 

(7) Be submitted to: Administrator, 

National Highway Traffic Safety 

Administration, 1200 New Jersey Ave. 

SE, West Building, Washington, DC 

20590. 


ddrumheller on DSK120RN23PROD with RULES3ER07JA25.049</GPH>

BASE 
Federal Register / Vol. 90, No. 4 / Tuesday, January 7, 2025 / Rules and Regulations 1353 

(b) Report content—(1) Basis for 

phase-in production goals. Each 

manufacturer must provide the number 

of passenger cars and trucks and 

multipurpose passenger vehicles with a 

gross vehicle weight rating (GVWR) of 

3,855 kilograms (8,500 pounds) or less, 

and buses with a GVWR of 4,536 kg 

(10,000 lb) or less manufactured for sale 

in the United States for each of the most 

recent three previous production years, 

or, at the manufacturer’s option, for the 

most recently ended production year. A 

new manufacturer that has not 

previously manufactured these vehicles 

for sale in the United States must 

submit a report at the end of the initial 

production year for the number of such 

vehicles manufactured during the initial 

production year. 

(2) Production. Each manufacturer 

must report for the production year for 

which the report is filed: the number of 

passenger cars and trucks and 

multipurpose passenger vehicles with a 

gross vehicle weight rating (GVWR) of 

3,855 kilograms (8,500 pounds) or less, 

and buses with a GVWR of 4,536 kg 

(10,000 lb) or less, that do and do not 

meet S13 of Standard No. 225 (49 CFR 

571.225). 

(3) Vehicles produced by more than 

one manufacturer. Each manufacturer 

whose reporting of information is 

affected by one or more of the express 

written contracts permitted by 

S13.2.1(c) of Standard No. 225 (49 CFR 

571.225) must: 

(i) Report the existence of each 

contract, including the names of all 

parties to the contract, and explain how 

the contract affects the report being 

submitted. 

(ii) Report the actual number of 

vehicles covered by each contract. 

§ 585.141 Records. 

Each manufacturer must maintain 

records of the Vehicle Identification 

Number for each vehicle for which 

information is reported under § 585.140 

until December 31, 2032. 

Issued in Washington, DC, under authority 

delegated in 49 CFR 1.95 and 501. 

Adam Raviv, 

Chief Counsel. 

[FR Doc. 2024–31142 Filed 1–6–25; 8:45 am] 

BILLING CODE 4910–59–P 


ddrumheller on DSK120RN23PROD with RULES3