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Effective December 1, 2020
It is illegal to sell the US regulated versions of the mifold range of booster seats outside of the USA in territories that have different regulatory standards. Therefore, the strict policy of Carfoldio Ltd. prohibits any US regulated versions of the mifold range of products being shipped to consumers outside of the USA. Doing so creates substantial liability to any US based retailer supplying product to non-US based addresses and consumers.
Child restraint systems (CRS) are required to protect children in collisions, which are still one of the leading contributors to childhood injury and death. CRS are among the most highly regulated consumer products in the world and carry significant liability. The sale and use of CRS are governed by regulatory requirements that cover many important aspects including design, testing, labelling, language, quality compliance, reporting and recall procedures. Each territory worldwide defines its own regulatory framework.
Carfoldio manufactures products globally that are specifically designed and tested to meet the regulatory requirements of different territories. These are not cosmetic differences. We manufacture different versions of our products for the USA, compared to mifold products produced for the rest of the world (RoW). The US products have different safety labeling and user manuals, the US versions are regulated according to the NHTSA standard FMVSS213. The RoW versions comply with specific United Nations requirements under the UN regulation UNECE R44/04 and other country specific regulations for Canada, China, Chile, South Korea and Taiwan.
THE US VERSIONS OF MIFOLD PRODUCTS COMPLY FULLY WITH THE US STANDARD FOR SALE IN THE USA. WE CANNOT GUARANTEE THAT THESE US VERSIONS COMPLY WITH THE REGULATORY REQUIREMENTS UNDER ANY OTHER STANDARD AND THEY ARE NOT CERTIFIED FOR SALE IN ANY OTHER COUNTRY EXCEPT THE UNITED STATES. IN THE INTERESTS OF PUBLIC SAFETY, OUR POLICY IS NOT TO PERMIT US-BASED RETAIL PARTNERS TO SHIP THE US REGULATED VERSION OF THE MIFOLD RANGE OF SEATS OUTSIDE OF THE USA UNDER ANY CIRCUMSTANCES.
Safe use of all CRS is heavily dependent on correct usage and installation. This is true for all CRS; however, it is especially relevant for the mifold range of products, which are unique and innovative products that work completely differently to all other standard booster seats.
It is essential that parents and caregivers receive a product that includes the appropriate local language instruction manual, instruction labels and warning labels. A correctly installed CRS will reduce the risk of injury or death. Incorrect use of a CRS can literally mean the difference between life and death for the user; this is well documented in global research reports.
CRS instruction manuals and labels are highly regulated. It is unsafe to sell a child restraint without the instructions and labels being clear and understandable. In every territory where Carfoldio supplies its products, we provide local labeling and instruction language combinations, even if not required by law. This is our commitment to child passenger safety and is a public safety issue. The US versions of the mifold range of products only carry instructions and labelling in English, tailored specifically for the US market and in compliance with US regulations.
While we never anticipate a recall, they can and do happen. Informing the appropriate customers is another critical life and death responsibility of CRS manufacturers. Our systems are designed to ensure that information on any recall is communicated as quickly as possible, to the relevant customers, in the relevant markets, in their local language. We ensure that each one of our distributors around the world can implement these processes. So that, in every territory where we supply, we implement a local language recall process, even if not required by law. This again, is our commitment to child passenger safety and is a public safety issue.
We only manufacture the US versions of the mifold range of products for the US market with a US registration card included in every package. In the event of a recall of US product we can only communicate this in English in the USA. International delivery of US versions will prevent us from properly informing all customers of a US version recall in other markets outside of the United States. We will not know to communicate the recall in other languages and to other countries or inform such foreign customers to immediately stop using and return their product.
SHIPPING US REGULATED PRODUCT OUTSIDE OF THE US IS NOT ONLY ILLEGAL ACCORDING TO MOST LOCAL REGULATORY AGENCIES, BUT CREATES SUBSTANTIAL LIABILITY TO ANY US-BASED RETAILER THAT SUPPLIES PRODUCT KNOWINGLY TO NON-US ADDRESSES AND CONSUMERS.
If you would like to discuss this policy in any further detail, please contact jon@sumroy.com
