Background: Proposal to update the regulatory requirements concerning the safety of restraint systems and vehicle anchorages

Transport Canada is proposing to develop amendments to update the regulatory requirements for the safety of child restraints and vehicle anchorages, and to introduce technical standard documents (TSD) to align with the recent United States (U.S.) regulatory changes. As there are issues with the availability of special needs child restraint in Canada, amendments to the regulations are also being considered to help improve the accessibility of special needs restraints in the Canadian market.

Summary of Canada’s path forward

The Motor Vehicle Restraint Systems and Booster Seats Safety Regulations (RSSR), under the Motor Vehicle Safety Act (MVSA), would be updated by replacing most of the content with references to the new TSD 213a Child Restraint Systems – Side Impact Protection and TSD 213b Child Restraint Systems.

The Motor Vehicle Safety Regulations (MVSR), under the MVSA, would be updated since the content of Canadian Motor Vehicle Safety Standard (CMVSS) 213.4 (built-in restraints) would be replaced with references to the specific requirements concerning built-in restraints found in TSD 213b.

The MVSR would be updated as the content of CMVSS 210.1 and 210.2 (vehicle anchorages) would be replaced by a new CVMSS 225 which would reference the new TSD 225 Child Restraint Anchorage System.

The Restraint Systems and Booster Seats for Motor Vehicles Regulations under the Canada Consumer Product Safety Act (CCPSA) would be updated to align with the changes proposed above.

How to read the proposed text of the TSDs

The Regulations incorporate by reference TSDs into the Canadian Regulations under the MVSA, these TSDs are reproduction of the U.S. Regulations, with adaptations for the Canadian context. All changes are noted in TSDs as follows:

Struck out portions indicate that the text is not being adopted in the requirements of the regulations. Note that in some cases, certain definitions may be struck out in the TSD, such as “child restraint system” because the definition needs to be in the text of the regulation, rather than the TSD, for the legal regulatory text to function properly.
Underlined portions indicate new requirements that have been added that do not exist in the U.S. Regulations but are required from the Canadian standpoint.

In the future, if a change needs to be made to the Regulation itself, such as the RSSR, it will need to go through the full regulatory process to amend the Regulation, which can take several years. On the other hand, if a change can be made within the TSD, due to an amendment in the U.S. Regulation for example, Transport Canada can issue a new version of the document quickly, reducing the time needed to implement the change. In cases like this, the process is significantly more efficient, which benefits all parties.

Recent U.S. changes

From 2022 to 2025 the National Highway Traffic Safety Administration published four final rules and one Notice of Proposed Rulemaking (NPRM) to amend Federal Motor Vehicle Safety Standard (FMVSS) 213 Child Restraint Systems and FMVSS 225 Child Restraint Anchorage Systems, as follows:

Final rule	Final rule U.S. Regulation	Change	Effective date
2022-06-30	213a	Adopted new child restraint side impact requirements	Originally June 30, 2025 Proposed new effective date December 5, 2026
2023-12-05	213b	Updated child restraints frontal impacts requirements	December 5, 2026
2024-10-09	213a and b	Revisions in response to Petitions for reconsideration	December 5, 2026
2025-01-07	225	Updated FMVSS 225 for child restraint vehicle anchorages	September 1, 2028
2025-05-30 NPRM	213a and b	Proposal to remove some regulatory requirements	December 5, 2026

Prior to the U.S. final rules, Transport Canada’s RSSR and CMVSS 213.4 were relatively aligned with FMVSS 213. Similarly, CMVSS 210.1 User-ready Tether Anchorages for Restraint Systems and Booster Seats, and CMVSS 210.2 Lower Universal Anchorage Systems for Restraint Systems and Booster Seats, were also relatively aligned with FMVSS 225.

The U.S. has introduced a series of changes to their child restraint and vehicle anchorage Regulations which aim to increase their safety. Transport Canada has assessed these changes and agrees that they should be considered to improve child passenger safety in Canada. Incorporating these changes into Canadian Regulations would maintain regulatory alignment with the U.S. As both the child restraint and vehicle regulatory frameworks and markets in Canada and the U.S. are highly integrated, incorporating the U.S. changes has the added benefit of reducing the regulatory burden on industry. Since child restraints are designed for both the U.S. and Canadian markets, the updates made to the Regulations would lead to the safer implementation of child restraints and vehicle restraint anchorages in vehicles and alignment would help to keep costs down, ensuring that Canadians have access to and choice of child restraints.

Child restraints and booster seats

Transport Canada would be proposing to amend the RSSR by incorporating by reference 2 new TSDs, TSD 213a – Child restraint systems – side impact protection and TSD 213b – Child restraint systems. These TSDs (discussed in more detail below) are reproductions of U.S. FMVSS.

RSSR and TSD 213a side impact requirements

TSD 213a would include new side impact safety requirements for child restraints meant to accommodate children who weigh less than 18kg, based on vehicle side impact test requirements.

The TSD would introduce a new side impact test bench, and a new 3-year-old side impact test dummy. These changes would require that side impact performance of the child restraints be considered in the design of restraints.

RSSR and TSD 213b frontal impact requirement

TSD 213b would replace much of the existing content of the current RSSR which has requirements representing frontal collisions in vehicles. The major changes from the current Regulation include:

New frontal test bench

A new frontal test bench, designed to represent the seats of modern vehicles, would replace the current test bench. Once the updated Regulations come into force, all newly manufactured and imported restraints would be tested using the new test bench at the time of production.

Rear-facing restraint testing mass

In the current Regulations, infant carrier style rear facing restraints with a weight capacity limit of over 10 kg are required to be tested with the 3-year-old (3YO) dummy, even though the dummy is too tall for this style of restraint. This has led to testing issues within the Canadian Regulations. To resolve this issue, the dummy testing requirements for rear-facing restraints would be modified. Restraints with a capacity of up to 13.6 kg would only be required to be tested with the 12-month-old dummy. Companies would still be free to market infant or rear facing restraints above a 13.6 kg capacity but would be required to use the 3YO dummy for testing. It is expected that with this change in testing requirements that maximum capacity of infant carrier style restraints would change to a 13.6 kg maximum capacity to avoid testing with a dummy that is too large for these restraints. Rear facing convertible style restraints are still anticipated to be designed and certified for weight capacities above 13.6 kg and be tested using the 3YO dummy.

Forward-facing minimum weight labelling

The child’s minimum weight to utilize a forward-facing restraint would be increased from 9kg to 12 kg. This would promote children to remain in rear-facing restraints longer.

Definition of child restraint system

To reference the TSDs properly, child restraint systems would encompass all devices that restrain children, or support children for vehicle seat belt use, including booster seats. However, infant restraints would no longer be separately defined as they are considered rear-facing restraints.

Head impact

In the testing requirements for head impact, the RSSR specifies an 80 g limit, whereas the U.S. uses a Head Injury Criteria (commonly referred to as HIC) formula. The 80 g limit has always been a requirement in the Canadian Regulations. Transport Canada is reviewing data submitted by manufacturers to determine if the HIC injury criterion should be adopted in the regulations instead of the g-force measurement.

Slow recovery energy absorbing foam

Transport Canada has the unique requirement for contactable surfaces of restraints to have an additional layer of slow recovery energy absorbing foam. After review, this requirement does not appear to add any head impact protection value, therefore, Transport Canada would remove this requirement as part of the amendments that Transport Canada would propose. The U.S. removed this requirement in 2003.

Restraint weight limits

In the U.S., restraint labels must include information about the maximum child weight allowed in the restraint based on the weight of the restraint, using the formula (child restraint weight + child weight < 29.5kg). This requirement is required as vehicle anchorages are not currently required to handle higher weights. Transport Canada issued a consumer advisory in 2016 because of this U.S. final rule. Transport Canada would adopt this requirement on the child restraint label, eliminating the need for the consumer advisory, as the information would be clearly stated on child restraint label.

Rebound requirements

In Canada, rear-facing child restraints are subject to a regulatory limit on rebound—the extent to which the restraint rotates toward the rear of the vehicle following a frontal collision. Transport Canada’s research indicates that this rebound involves minimal residual energy and does not impact safety. Based on these findings, Transport Canada would be proposing to remove this requirement.

General labelling requirements

Previous research has shown that child restraints in vehicles are often misused, such as having the restraint improperly tightened in the vehicle or the harnesses incorrectly adjusted for the child. To address this issue, Transport Canada proposes removing many of the current requirements for written warnings, which occupy a significant portion of the available space for labelling on the restraint. Instead, Transport Canada would be proposing to require labels to be designed with features such as pictograms, colour coding, and highlighting critical tasks to effectively communicate the proper use of the restraint.

Special needs restraints

Current issues

Special needs restraints are intended for occupants who have physical or mental needs that are not accounted for by conventional restraints. These products have unique designs or added features to support the needs of the occupant. For example, a car bed is intended for a child who must always lie flat.

Existing frameworks are in place to direct caregivers towards the purchase of special needs restraints as they are not available for general sale, however, there are very few products available in Canada as compared to the U.S. This lack of product availability has forced users to purchase products in the U.S. for private importation which are rarely also compliant to RSSR requirements.

In Canada there are two federal regulations that regulate child restraints that are not built into vehicles. Transport Canada regulates child restraint manufacturers and companies that import child restraints under the MVSA. Under the CCPSA, Health Canada’s Restraint Systems and Booster Seats for Motor Vehicles Regulations, include items such as sale, advertising, and personal import. These complementary regulatory regimes help ensure that all products manufactured, imported and available for sale in Canada meet RSSR requirements.

Health Canada’s regulations reference Parts 2–4 of the RSSR, and do not include special needs restraints, which is the reason a consumer can privately import a special needs restraint into Canada that does not meet the Transport Canada regulations. If one of the U.S. restraints if found to have a safety defect, Transport Canada has no authorities for the oversight and enforcement of restraints not originally sold in Canada, thus it could not require manufacturers to issue a notice to consumers informing them of a potential safety issue.

Provincial considerations

Many provinces/territories provide funding towards the purchase of a special needs restraint, however the provinces/territories require a Canadian compliant restraint with a National Safety Mark on the product to obtain funding. A National Safety Mark is a Canadian Government trademark applied to a child restraint that signifies that the restraint has been certified as meetings all applicable Canadian federal safety requirements. A manufacturer must request authorization to apply the National Safety Mark for Transport Canada. If a restraint is purchased in the U.S., and does not have a National Safety Mark, it may not be eligible for provincial funding. In Quebec funding is available for restraints purchased in the U.S. that do not comply with Canadian safety requirements, but an exemption is required for approval. This process can take many weeks, and in some cases, by the time the approval has been granted, the child may not need the special needs restraint anymore (like in the case of recovering from a medical procedure).

Airline travel

To comply with the RSSR, most child restraints must be tested for aircraft use. In the U.S., testing for aircraft use is optional. Transport Canada has been made aware that there are instances where children in remote communities must be flown to another location to receive health care. If the child requires the use of a special needs restraint, and only a restraint that is not meant for airline use is available, the restraint cannot be used during the flight. This may place the child at risk of injury due to the lack of necessary support. Transport Canada proposes to require special needs restraints that can fit in an airline seat be certified for aircraft use.

Changes being considered to accommodate special needs

Disabled person

The disabled person definition would be updated to align with the persons with disabilities definition in the Employment Equity Act, which would encompass many disabilities.

Special needs forward and rear-facing restraints

As is currently the case, there would be no difference in the testing requirements from non-special needs restraints, however, the restraints would require a label specifying that the restraint is intended to be used by special needs persons.

Special needs boosters

As is currently the case, there would be no difference in the testing requirements from non-special needs boosters, however, special needs boosters would allow for internal harnesses to assist with positioning and supporting occupants in their restraint. The special needs boosters would require a label specifying the restraint is intended to be used by special needs people

School bus restraints and special needs school bus harness

School bus restraints that use webbing to wrap around a school bus seat back to secure it to the school bus seats where no seat belts or anchorages are present are part of the current regulations for special needs children. The U.S. has added these restraints into the U.S. regulations. Transport Canada proposes align with the U.S. requirements, however the restraints would continue to be only intended and labelled to be used only for children with special needs.

Special needs belt-positioning harnesses

These harnesses would be intended for occupants with special needs while using a seat belt, with or without a booster seat. The RSSR does not currently have a category for belt positioning harnesses, while the U.S. does. These products were initially intended to support occupants when only a lap belt was required in the rear seat of vehicles and the occupant required torso support. Transport Canada would be proposing to adopt belt-positioning harnesses in the Regulations with the following requirements:

No bench testing required as they would be intended to be used with a seat belt for positioning purposes
Child minimum weight of 18kg to support those who transition out a child restraint into a booster seat
Label informing that the harness should only be used with a lap and shoulder belt, or a lap and shoulder belt with a booster seat
Label informing that the harness would be for seat belt positioning and intended only to be used with people with special needs

Categories of restraints

To promote compatibility with provincial/territorial jurisdictions, Health Canada regulations, and Transport Canada’s aviation Advisory Circular, the proposal would modify the child restraint category listed beside the National Safety Mark as follows:

Current	Proposed
CMVSS 213 (Child Restraint Systems)	CMVSS 213 (Child Restraint Systems)
CMVSS 213.1 (Infant Restraint Systems)	Remove moving forward
CMVSS 213.2 (Booster Seats)	CMVSS 213.2 (Booster Seats)
CMVSS 213.3 (mass-produced restraint system for disabled persons) and (custom restraint system for a disabled person that is designed to be used only in school buses)	CMVSS 213.3 (Special needs child Restraint System)
CMVSS 213.5 (Restraint Systems for Infants with Special Needs)	Remove moving forward
	CMVSS 213.6 (Special needs belt-positioning harnesses)
	CMVSS 213.7 (School bus restraints)

Transport Canada would propose to remove CMVSS 213.1 and 213.5 as infant restraints would no longer be a separate category of restraint in the proposed requirements. CMVSS 213.3 currently has categories for mass produced child restraints for disabled persons which would be renamed to reflect the new name of special needs child restraints. CMVSS 213.3 also has custom restraints for school buses. We are unaware of any school bus products being sold in Canada that are custom vs mass produced which have the CMVSS 213.3 designation in Canada. As a result, to better communicate the child restraint category CMVSS 213.7 will be created to signify school bus restraints that are specifically manufactured for use on school bus seats without the use of seat belts or vehicle anchorages for child sets. CMVSS 213.6 would be added to designate Special needs belt-positioning harnesses. This list ensures that existing restraints used by caregivers can still be properly identified and not conflict with the information for existing restraints on the market.

Vehicle anchorages for child restraints

Transport Canada is proposing to repeal the vehicle anchorage Regulations CMVSS 210.1 and 210.2 and combined into CMVSS 225. In addition, the following changes would be made from the current Regulations:

Lower anchorage clearance angle and depth limit

Lower anchorage clearance angles and depth limits are proposed to be added to improve the fit, and stability of installed restraints, and provide consistent protection across different vehicle models.

Tether anchorage shape and placement

Transport Canada is proposing to modify the zone of allowable tether anchorage placement to prevent tether anchorages under the seats of most vehicles, and to standardize tether anchorage shape. In cases where the tether anchorage location may be inaccessible, such as a pickup truck, an allowance would be included so that the anchorage may have an extender strap.

Tether anchorage minimum length

The tether hook of a child restraint is proposed to be limited in the length that the tightening hardware can be from the actual tether hook. The tether anchorage point on a vehicle would require a minimum distance in how far it can be from a seat back. These changes would improve the ability for users to tighten the tether anchorage of a restraint to a vehicle.

Built-in restraints in vehicles

The requirements for restraints that are built-in to the vehicle would be in TSD 213b, therefore Transport Canada is proposing that the contents of CMVSS 213.4 of the Motor Vehicle Safety Regulations be replaced with a reference to the built-in restraint requirements in the new TSD 213b.

Regulatory burden

These regulatory changes would advance Transport Canada’s Red Tape Review, by aligning with international standards and enhancing industry flexibility. The harmonization of the Canadian Regulations with the U.S. Regulations, are expected to increase the availability of special needs products in Canada.

Regulatory amendments

Given the extensive engagement already undertaken—and the continued engagement planned—Transport Canada is assessing the potential to publish the final regulatory amendments directly in the Canada Gazette, Part II, by seeking an exemption from the usual pre-publication in the Canada Gazette Part I. This would significantly shorten the process of updating the Regulations. To accommodate this, Transport Canada would continue engagement and be transparent with stakeholders by consulting on draft regulatory and TSD text. In the future, if stakeholders respond with no further concerns and support a direct to Part II publication, Transport Canada intends to seek exemption from pre-publication requirements.

To maintain marketplace stability following future amendments to the RSSR, Transport Canada is working with Health Canada to keep the Restraint Systems and Booster Seats for Motor Vehicles Regulations under the CCPSA aligned with the MVSA requirements. It is proposed that these regulations be updated to reflect changes to the RSSR, ensuring a consistent approach. This alignment would help guarantee that retail inventories of child restraints continue to meet key health and safety standards after any future regulatory amendments.

Coming into force

The Regulations are proposed to come into force on the date of publication in the Canada Gazette Part II, with mandatory compliance 2 years after the publication in the Canada Gazette Part II.

Key questions

Transport Canada is managing responses to the first 3 questions. Please email your response to questions 1,2, and 3, to RegulationsClerk-ASFB-Commisauxreglements@tc.gc.ca and include “Updating Child Restraint and Vehicle Anchorage Regulations” in the subject line.

Do you have any feedback on the reference documents provided below?
Do you have any feedback or concerns about Transport Canada skipping the usual pre-publication phase and publishing the updated regulations directly to the Canada Gazette, Part II?
Do you have any feedback on the proposed timeline for when the changes will come into force?
1. The restraint regulations would come into force 2 years after being published in the Canada Gazette, Part II
2. The anchorage regulations would come into force on September 1, 2032

Health Canada is managing responses to the last question. Please email your response to question 4 to ccpsa-lcspc@hc-sc.gc.ca and include “Updating Child Restraint and Vehicle Anchorage Regulations” in the subject line.

How much time should companies have to comply with the new, mandatory requirements under the Restraint Systems and Booster Seats for Motor Vehicles Regulations?

Reference documents

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Proposal to update the regulatory requirements concerning the safety of restraint systems and vehicle anchorages

Transport Canada
Place de Ville, Tower C
330 Sparks St
Ottawa ON K1A 0N5
Email: RegulationsClerk-ASFB-Commisauxreglements@tc.gc.ca