In January, NHTSA issued a final rule to improve the usability of the LATCH system. To read the rulemaking document, click here or search Docket No. NHTSA-2024-0089 at www.regulations.gov.
Most aspects of the new rule apply to FMVSS 225, directing vehicle manufacturers to further standardize several aspects of lower anchors (LAs) and tether anchors (TAs). The rule also includes a few new requirements for CRs and will amend the upcoming FMVSS 213b.
Improved LATCH usability is expected to translate to fewer installation errors by caregivers, and NHTSA asserts that even small improvements on this front can save lives. The agency states, “These new usability requirements will assist in improving correct (tight) installation and increase tether use. If there were a 5 percent increase in correct installation using the lower anchors and a 5 percent increase in tether use, the agency estimates that the proposed requirements would save approximately 3 lives and prevent 6 moderate-to-higher severity injuries per year.”
As of September 2028, CR manufacturers will be required to comply with the updates to FMVSS 213b, though it is likely that many will strive to meet this part of the standard when they meet other aspects of the new standard, no later than December 5, 2026. Vehicle manufacturers have been granted a a three-year phase-in period for compliance starting on that date and ending September 2031. Early compliance for all aspects is allowed. Note: The current federal regulatory freeze could affect any of these deadlines.
It has been 10 years since NHTSA issued the Notice of Proposed Rulemaking (NPRM) for this final rule. NHTSA says that the final rule adopts most of the proposals in the NPRM, but a few were not adopted, and the provisions of nearly all were adjusted to some extent. Here are the main elements of the rule.
LATCH Marking in Vehicles
The rule strives to improve LATCH use by making anchors easier to spot. The current regulation requires a LATCH symbol to mark LAs only when they do not meet a specified visibility requirement, and there is no requirement for marking a TA (though many vehicles today follow voluntary industry standards for TA marking).
The new rule will require LAs and TAs in all vehicles to be marked using the icons developed by the International Standards Organization (ISO), which are essentially the same symbols that CPSTs are already familiar with for these anchors. There are also new rules for the placement of markings relative to anchors; these will require some manufacturers to relocate their existing markings in some vehicles. There is also a new requirement that a TA must be closer to the marking than any other non-TA hardware that could be mistaken for the TA.
Perhaps the most noticeable new markings will be those required on cargo covers that, when in use, block the visibility of TAs (which is typically the case). NHTSA leaves the location of the symbol on the cover to the manufacturer’s discretion. Even when a cargo cover is marked, the TA under the cover must also follow the standard’s TA marking requirements.
LATCH Marking on CRs
The main application of the new rule for CR manufacturers is the requirement for CRs to display symbols on (or a specified distance from) a CR’s LA connectors and tether hook. Since the symbols match those required in vehicles, this new CR feature (which has long been required in Canada) is expected to help consumers recognize how the parts on CRs match up to the parts in vehicles.
Although NHTSA didn’t require a particular color or contrast for these markings, the agency says it encourages manufacturers to make the markings as visible as possible.
Lower Anchorage Ease of Use
Requirements that will make it easier to access vehicle LAs are a significant part of the new rule. The NPRM proposed limiting how deep LAs may be located within the bight, the extent to which other vehicle parts can crowd the LAs, and how much force is required to attach an LA connector. NHTSA proposed measuring each of these aspects using specified tools.
The final rule adopted the NPRM’s suggested clearance angle of 54 degrees to limit how close other vehicle parts may be to the LAs. It also sets a new maximum LA depth, though that will be 25 mm within the bight rather than the proposed 20 mm. (Either distance is closer to the front of the bight than what FMVSS 225 currently allows, though direct comparison is difficult because the current depth is within a zone measured using two different vehicle reference points.) Modifications were also made to the measurement tools for these metrics to improve repeatability and reproducibility.
The new rule did not adopt the force limit for LA attachment that NHTSA had originally proposed. In testing, the agency agreed with commenters that repeatability and reproducibility were not consistent enough to warrant implementing this requirement. The agency noted that implementing the clearance angle and anchor depth requirements is likely to lessen the force needed to attach CRs to LAs.
Tether Anchorage Ease of Use
The final rule states, “Tether anchorages must be easy to use, as they are the primary factor behind the estimated 36–50 lives saved a year following NHTSA’s adoption of FMVSS 225.”
To this end, in addition to the tether markings mentioned previously, the new rule requires that a tether anchor not be located deep under a vehicle seat (though placement very low on the seat base or floor will still be allowed).
The rule also addresses the problem of TAs being too close to the CR, making it impossible to tighten the tether properly because the length of the tether hardware (the distance from the hook to the end of the adjuster) is longer than the distance from the CR to the TA. FMVSS 225 will require the TA to be far enough away that the tether can be tightened. Under the new rule, a CR’s tether hardware may be no more than 165 mm (6.5 inches) long. NHTSA notes that most CRs already comply with this tether hardware length.
TA obstructions, other than a marked cap, flap, or cover, will be prohibited. NHTSA clarified that such obstructions include scored seatback fabric that covers TAs, as well as cargo floors that block TAs when they abut a vehicle seatback (i.e., the TA is located lower than the cargo floor). The current standard allows caps, flaps, or covers to be openable using a tool like a coin or screwdriver; the allowance for using a tool has been removed in the new rule.
TA Design
Currently, FMVSS 225 does not specify design characteristics for TAs. The final rule will require most TAs to be a “rigid bar of any cross-section shape.” However, the rule will make exceptions for certain vehicles with space issues, including pickups, convertibles, and large vans (defined as buses weighing 10,000 lbs. GVWR or less that seat 10 or more people). Since these excepted vehicles are currently the only kind with TAs that aren’t rigid bars, this ruling is unlikely to necessitate many changes to current designs.
Another part of the rule that will require some vehicle redesign, especially for pickups, prohibits situations in which a seatback must be folded to reach a TA. The agency concluded that it is more difficult to install a CR using this method, as it may require several extra installation steps to achieve a tight installation, and there is a risk that the folded seatback will not relock properly. It stated that pickup designs that currently require the vehicle seatback to be folded to access the TA can be modified to include flexible tether anchorages (that may also be used as routing devices). In other words, while the agency acknowledged that tethering systems that involve routers are more difficult for consumers to use than rigid TA bars, in space-constrained vehicles, they are better than the alternative of a direct tethering system that requires the seatback to be folded forward.
LATCH Exemptions
Convertible vehicles and some other (mostly one-row) vehicle designs that were formerly exempt from LATCH requirements will no longer be exempt under the new rule. To allow ample time for necessary redesign, manufacturers will be given six years to comply with this aspect of the rule.
LATCH Terminology
In the NPRM, NHTSA also requested comment on whether requiring the following terms in CR and vehicle user’s manuals would help make instructions clearer and more uniform: ‘‘lower anchor(s)’’ and ‘‘tether anchor’’ for vehicle LATCH components, and ‘‘lower anchor attachments’’ and ‘‘tether’’ for components of the CR that are used to connect it to the vehicle. A ‘‘lower anchor attachment’’ is comprised of a ‘‘lower anchor connector’’ and a ‘‘lower anchor strap’’ (for flexible lower anchor attachments), and a ‘‘tether’’ is comprised of a ‘‘tether hook’’ and a ‘‘tether strap.’’
Upon consideration, NHTSA ruled that these terms should be used consistently in the owner’s manuals of vehicles and CRs, which will require updates to many manuals, especially those for vehicles. (The LATCH Manual and the 2024 CPST Curriculum already use these terms.)
Note: Readers may not realize that NHTSA’s terminology for universal anchorage is “child restraint anchorage system,” or CRAS, not LATCH. The final rule specifies that CR and vehicle manufacturers may continue to refer to LATCH, the industry-adopted and commonly used terminology, in manuals and on labels. However, NHTSA states that it will continue to use the term CRAS, including for some required labeling.
NHTSA Tethering Endorsement
The NPRM asked for comment on whether TAs should have stated weight limits. In its 2012 and 2014 final rules establishing child weight limits for using LA attachment, the agency was clear that it saw no reason to place such limits on tethering, but the NPRM’s request for comment gave manufacturers and others the opportunity to provide further evidence on this point.
Having reviewed the comments and all supporting information, including from vehicle manufacturers and their trade group, NHTSA’s official stance continues to be that tethers should be used at all times with forward-facing CRs. However, the agency has not made this statement a requirement in CR or vehicle instructions.
Do New Regulations Affect the LATCH Manual?
Rest assured, the new LATCH usability standards described in this issue do not affect the accuracy of the 2025 LATCH Manual. The new, blue edition provides up-to-date information from CR and vehicle manufacturers.
The rule’s requirements do not go into effect for at least three years, and any changes that are made to existing or new models to meet standards will be reflected in upcoming editions of the LATCH Manual. Likewise, LATCH Manual chapters that describe LATCH details will remain accurate for the duration of the current edition, which runs through 2026.
For a future edition, SRN will edit the LATCH Manual chapters to give a complete account of newly standardized features. SRN will align those updates with the applicability of the new standard, though that process is currently in limbo. If cleared to take effect after regulatory review (see page 1 of the January/February 2025 issue), vehicle makers have three years before beginning a three-year phase-in period for compliance. Therefore, it may be an edition or two before the rule prompts noticeable LATCH Manual edits.
However, as a rule, change is constant! Watch for future updates to the current LATCH Manual here. To get an email announcement when updates are posted, use the sign-up tool here