Evaluation of Child Safety Seat Registration

Beginning March 1993, Federal Motor Vehicle Safety Standard 213 required manufacturers to provide a postage-paid registration form with each new child safety seat sold, with the goal of increasing consumer response to child seat recalls. Before March 1993, registration was voluntary for manufacturers.

It is estimated that registration increased from 3 percent prior to 1993, to an average 27 percent over the years 1996 through 2000. Based on data from 1990 through 2000, the repair rate for recalled child seats also increased, from 13.8 percent before the registration requirement to 21.5 percent once the requirement was in effect. The cost to consumers for child seat registration and notification is approximately 43 cents per seat sold in the United States.

Beginning March 1993, Federal Motor Vehicle Safety Standard (FMVSS) 213 (Child Restraint Systems, 49 CFR 571.213) required manufacturers to provide a postage-paid registration form with each new child safety seat. This was done to improve consumer response to child seat recall campaigns. The format of the card was specified, with information pertaining to the seat pre-printed, to make it as easy as possible for consumers to register their seats. The card was attached to the seat at a location where owners would see it and handle it before they could buckle a child in the seat. Prior to the 1993 requirement of registration cards, an estimated three percent of consumers registered their child seats. Currently, the registration rate is 27 percent, according to data from the manufacturers.

What has happened to the repair rate for recalled child safety seats? There are various ways to determine the average repair rate. The preferred method in this report is to compute the percentage of seats repaired in each recall, and then take the average across recalls. Data were examined for the years 1990 through 2000. Before the rule took effect in 1993, the average repair rate was 13.8 percent. After registration cards were required, the rate rose to 21.5 percent, a 56 % increase. This 7.7 percentage point increase is statistically significant. This report will show that the 7.7 percentage point increase is consistent with expectations based on the increase in registration from 3 to 27 percent, the likelihood that consumers learn about recalls via a letter from the manufacturer as opposed to other information sources, and how frequently consumers aware of a recall actually have the seat repaired. In other words, a substantial portion, and possibly most of the 7.7 percentage point increase in recall repairs, is due to safety seat registration, although some of it may be due to other factors that increased consumer awareness of child passenger safety. These benefits have been realized at a consumer cost of about 43 cents for each seat sold in the U.S.

Other methods of computing repair rates are considered in the report, and yielded similar results. Repair rates can vary greatly from one recall to another, depending, for example, on how promptly a defect is identified, and consumers' perceptions on the seriousness of the defect. Therefore, to discern a meaningful trend, it is important to average repair rates over several years and numerous recalls, and not to be overly concerned about large swings in the repair rate from one year to the next.

Data from several sources were incorporated in this report. NHTSA's Office of Defects Investigation (ODI) provided consumer registration and recall compliance records from child seat manufacturers. Consumers, both the general public (General survey) and those known to have experienced a recall (Recall survey), were surveyed on registration and recall activities, as well as other related topics. Dealers that sell child seats were queried regarding such topics as discussing registration with consumers and providing recall information. Interviews were also completed with loaner programs, both those associated with public health agencies and those with a hospital affiliation.

One discrepancy in this evaluation is that hard data submitted by the manufacturers show an actual registration rate of 27 percent, whereas respondents in the General survey self-reported registering at a rate of 62 percent. There is no doubt that the 27 percent rate is the correct one for the overall population. The registration rate in the General survey is high presumably because (1) the type of people recruited to participate in the survey are more likely to register their seats, and (2) in addition, some may be reporting inaccurately that they registered their seats. (Similar overreporting occurs in telephone surveys of self-reported belt use.) However, this study does not use the survey to estimate overall registration rate, but rather uses the self-reports to assess consumers' feelings about recalling seats, why people do and do not register their seats, and similar topics. The important findings of the General survey - that child seat registration and the recall of unsafe seats are important to consumers, that people not registering do so because they are "too busy" and not because they are hostile to the registration process or fear how their information will be used, and that consumers receive little advice about registration when they acquire their seat - are most likely not affected by these biases.

The repair rate of 21.5 percent was determined using a specific set of recalls. Those involving label corrections only were excluded, since they are considered unverifiable. Recalls that were too recent to have reported the required six quarters of data, those involving small companies producing a limited number of seats, and those involving companies that had gone out of business were also excluded from the rate determination.

When a recall occurs, about 22 percent of those that registered their child seat first hear of it from the manufacturer's letter. Regardless of how they first find out, approximately 56 percent of people in the General survey who said they registered remembered being notified by the manufacturer. These rates could be low if some of the participants in the General survey who claimed they registered their seats, in fact, did not. In addition, some consumers may have moved and not had the notice forwarded to their new address. When data from the ODI audit are included, which was limited to people who definitely registered their seats, over 77 percent remember hearing from the manufacturer. Along with notification from the manufacturer, many consumers, whether registered or not, first find out about a recall either from a television announcement or by hearing the information from a friend or relative. A large group of unregistered owners also read about the recall in a newspaper or magazine, and others learn about them from notices posted in retail stores.

Many consumers cannot be reached by a letter from the manufacturer. About 73 percent of consumers have not registered, so contact information is unavailable. Even among those that do register, this information can become obsolete when they move and fail to notify the manufacturer. Census data suggest that about 23 percent of child seat owners may have moved within the first year, 41 percent after two years, and 54 percent within three years of purchasing the seat. This leaves less than half the child seat owners at their address of record three years after registering. Child seats are often passed on to friends or family as children grow. About 16 percent of consumers surveyed were not the original owner of the seat currently in use. Few subsequent owners register their seats, although provisions are made to allow for this. Considering these factors, manufacturers would be able to reach between 21 and 27 percent of child seat owners after one year, and only about ten to thirteen percent after three years.

The amendment to FMVSS 213 required a label on the child seat to provide the manufacturer's contact information for second and subsequent owners to register the seat. NHTSA also offers a form on its website that can be used to register the seat with the manufacturer. More could be done to advise consumers of the availability of this. Similarly, consumers can notify the manufacturer when they move, in order to keep contact information current. Programs aimed at reminding seat owners to do this could increase the number of registered owners that can be reached by the manufacturer in the event of a recall. For example, the U.S. Post Office provides checklists and information on what to do when moving. Adding a note on updating contact information for registered child seats could serve as a reminder for seat owners.

While the current report stresses the importance of registering child seats, other methods of recall notification are clearly both important and necessary. Television programs, newspapers, and magazines providing announcements on recalls, as well as stores posting recall notices, are to be commended on the job they do of reaching consumers who would not have otherwise known about the recall.

Consumers that comply with child seat recalls generally find it easy to contact the manufacturer, the instructions easy to understand, and the repairs easy to perform. Consumers that are aware of recalls, for the most part, do follow through and fix the seat. The majority of those that are aware of a recall but do not repair their seat have an appropriate reason, such as no longer using the seat.

While the repair of unsafe child seats has increased since registration cards were required, there is ample room for even greater improvement. A very few consumers are openly hostile to the registration card and unwilling to provide the necessary information. About two percent of respondents stated they did not register because they were concerned about the possible use of the information they would need to provide. Most consumers that did not register, about 85 percent, stated they were just too busy and never got to it. In reality, very little effort is required on the part of the consumer.

Adding a space for an e-mail address on the registration form could make initial recall notification faster. It could also be helpful in locating seat owners that have changed residence but retained their e-mail address. Another way NHTSA could help publicize recalls would be to promote the Consumer Products Safety Commission recall notification subscription list. The CPSC offers a free e-mail service in which subscribers are notified of CPSC press releases, including recalls. Options are available to restrict mailings to recalls only, or just those recalls presenting a risk to children. NHTSA could mention these e-mail lists in its child-related safety materials as well as providing a link on its web page.

NHTSA could increase registration with programs aimed at those groups that currently have low registration rates. According to the consumer survey performed for this report, the lowest registration rates were among those in the lowest income group, those with less education, and younger seat owners. Older, more educated consumers, and those with higher incomes, were more likely to register their child seats, as were consumers who spoke with someone about registration at the time they obtained their seat.

Dealers do provide information regarding child seat registration and recall, but much more could be done to support them in encouraging customers to register their child seats. Only about three percent of consumers purchasing a seat remember discussing registration with a store employee. Consumers were more likely to discuss registration when the seat was received as a gift than when it was purchased. When registration was discussed with someone at the time the seat was acquired, the registration rate increased by about seven percentage points. This is true whether the seat was purchased, and the purchaser discussed registration with someone at the store, or received as a gift, at which time the recipient may have discussed registration with the gift-giver.

The survey of dealers indicates that some types of stores do a more thorough job of keeping consumers informed about registration and recalls. Further study in this area is suggested to provide information on what types of stores might offer the largest gains from programs aimed at increasing child seat registration as well as recall notification and compliance. Store management, as well as local child safety organizations, could work to support dealers in getting more information to their customers. Dealers could be provided with a brochure outlining registration benefits, as well as how easy the process is, to hand to the customer with each child seat purchase. The brochure could also suggest that those purchasing the seat as a gift offer to register the seat in the name of the busy new parents. This small procedure could do much to increase registration.

Although only about one percent of consumers obtain their child seat from a community-based loaner program, such programs offer an important service. While many provide child seats to those that could otherwise not afford them, other programs serve to make the usage of child seats more likely. For example, there are programs that focus on loaning seats to grandparents for visiting grandchildren, who otherwise might ride unprotected during a vacation visit. Other programs provide seats for children with temporary medical conditions, who are better protected in a specific type of seat. Loaner programs do a good job of providing training for using child seats and often assist in registering the seat, as well as monitoring for recalls on the seats they loan.

Requiring registration cards has increased recall compliance at a low cost to consumers. Further steps can be taken to achieve even further improvements.