The National Highway Traffic Safety Administration (NHTSA) published the below notices of final rulemaking this month. Specifically, NHTSA published one correction to its recent final rule on child restraint systems, and two notifications of enforcement discretion announcing that it would not enforce the requirements of two of its new final rules until March 20, pursuant to the “Regulatory Freeze Pending Review” presidential memorandum. The agency did not take further actions on these rules after March 20 and they remain effective.

  • Federal Motor Vehicle Safety Standards: Child Restraint Systems, Child Restraint Anchorage Systems, Incorporation by Reference; Correction (March 3): NHTSA corrected its January 7, 2025 final rule amending FMVSS No. 225 (child restraint anchorage systems) and FMVSS No. 213b (child restraint systems) to clarify the compliance date for the FMVSS No. 213b amendments. The final rule has been corrected to provide that: (1) vehicle manufacturers will have a three-year phase-in period to comply with the updated requirements to FMVSS 225, with 100 percent of vehicles to be updated by September 1, 2030; and (2) child restraint systems manufacturers must comply with the amendments to FMVSS No. 213b by January 8, 2028. The correction makes further amendments to clarify that the amended rules will only apply to child restraint systems manufactured after January 8, 2028, and that child restraint systems manufactured prior to January 8, 2028 may continue to comply with the current requirements.
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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.

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.