The National Highway Traffic Safety Administration (NHTSA) published the below notices of final rulemaking in the Federal Register this month. See below for brief summaries of the new rules and compliance dates for manufacturers.

  • Federal Motor Vehicle Safety Standards: Occupant Crash Protection; Seat Belt Reminder Systems; Controls and Displays (Jan. 3): NHTSA amended FMVSS No. 208 (Occupant Crash Protection) to extend existing seatbelt warning systems to: (1) require a seat belt warning system for rear seats, (2) update and enhance seat belt warning requirements for driver seat belt warnings, and (3) extend the requirements for driver’s warnings to the front outboard passenger seat. Manufacturers must comply with the front set belt warning system requirements by September 1, 2026, and the rear seat belt warning system requirements by September 1, 2027, with an additional year for multi-stage manufacturers and alterers.
  • Anthropomorphic Test Devices: Hybrid III 5th Percentile Female Test Dummy; Incorporation by Reference (Jan. 3): NHTSA updated requirements for the Hybrid III 5th percentile adult female (HIII-5F) anthropomorphic test device (ATD or crash test dummy or dummy) used in the frontal compliance crash and air bag static deployment tests required to certify compliance with FMVSS No. 208 (Occupant Crash Protection). The new rule amends 49 C.F.R. part 572, subpart O to include changes to the specifications for test dummies’ chest jackets and spine boxes. The effective date of the rule is February 18, 2025.
  • Federal Motor Vehicle Safety Standards: Child Restraint Systems; Child Restraint Anchorage Systems; Incorporation by Reference (Jan. 7): NHTSA amended FMVSS No. 225 (Child Restraint Anchorage Systems) and FMVSS No. 213b (the new standard for Child Restraint Systems which becomes mandatory for child restraint manufacturers on December 5, 2026) to improve usability of child restraint anchorage systems. The final rule amends FMVSS 225 to require vehicle manufacturers to adopt: a required “clearance angle” and “anchorage depth limit” to improve consumer ease; improved test tools for measuring required angles and depths; additional tether anchorage location requirements; standardized configuration of anchorages; and standardized markings to be used to identify vehicle anchorages. The final rule also amends FMVSS 213b to require child restraint system manufacturers to (1) use the standardized symbols to identify child restraint components that attach to vehicle anchorages, and (2) ensure that tether hook and attachment hardware on child restraint systems are limited in length. Vehicle manufacturers will have a phase-in period to comply with the updated FMVSS 225 requirements, beginning on September 1, 2028, with all anchorage systems expected to comply with the new rule by September 1, 2030. Child restraint system manufacturers must meet the additional requirements for FMVSS 213b by September 1, 2028.

Tags: Federal Motor Vehicle Safety Standards, NHTSA
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Photo of Rachael Padgett Rachael Padgett

Rachael Padgett’s practice focuses on the intersection of litigation and regulatory counseling, and she has a passion for advising clients on how to navigate product risk and achieve creative solutions.

As a counsel in the Litigation and Transportation Groups, Rachael handles matters involving…

Rachael Padgett’s practice focuses on the intersection of litigation and regulatory counseling, and she has a passion for advising clients on how to navigate product risk and achieve creative solutions.

As a counsel in the Litigation and Transportation Groups, Rachael handles matters involving product liability litigation, supply chain contract disputes, National Highway Traffic Safety Administration and Department of Transportation regulatory counseling, and Consumer Product Safety Commission reporting and investigations. With a focus on the transportation, micromobility, railroad, and retail product industries, she represents clients facing complex, high-stakes problems using a thoughtful, human approach to minimize client exposure and resolve disputes effectively.

Rachael maintains a pro bono practice with a focus on representing children in immigration cases and as guardian ad litem.

During law school, Rachael served as articles editor for The George Washington Law Review and received numerous awards, including the Jacob Burns Award for the First Place Team in the Van Vleck Constitutional Law Moot Court Competition, the Henry R. Berger Award for Excellence in the Area of Tort Law, and the Jennie Hassler Walburn Award for Excellence in the Area of Civil Procedure. She also worked as a judicial intern for the Honorable Michael O’Keefe in the Superior Court of the District of Columbia’s Family Court and regularly volunteered at the Family Court Self-Help Center.

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Photo of Rebecca Baden Chaney Rebecca Baden Chaney

Rebecca Baden Chaney is a partner in the firm’s Washington, D.C. office and is co-chair of the firm’s Transportation Practice. Transportation, micromobility, consumer, and other product manufacturers lean on Rebecca Chaney’s keen understanding of the transportation and consumer product industries and the legal…

Rebecca Baden Chaney is a partner in the firm’s Washington, D.C. office and is co-chair of the firm’s Transportation Practice. Transportation, micromobility, consumer, and other product manufacturers lean on Rebecca Chaney’s keen understanding of the transportation and consumer product industries and the legal landscape to advance their businesses. Rebecca applies her commercial-focused product risk lens to represent product manufacturers facing litigation, commercial, and regulatory challenges.

Rebecca is an industry-recognized force in litigating complex product-related warranty, defect, indemnity and contractual commercial disputes, and consumer litigation, including in class actions and mass tort proceedings. She counsels her commercial clients on product disputes, risk mitigation, and crisis management matters. Rebecca additionally defends clients against defamation claims. Clients appreciate Rebecca’s close coordination with them, her proactive approach, and her critical and creative thinking about each stage in a litigation or matter.

Rebecca’s approach embraces product liability risk management across the life cycle of product commercialization, from pre- to post-launch to aftermarket. This includes advice on product labeling, as well as National Highway Traffic Safety Administration and Consumer Product Safety Commission regulatory compliance, recall, and enforcement issues.

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