Last updated: Wednesday, August 18, 2016

Policy: International Sales of the US Version mifold Grab-and-Go booster outside of the USA

Dear US Retail Partner,

Carfoldio Ltd. has a strict policy regarding shipping the US version mifold Grab-and-Go booster seat outside of the United States.

Policy

It is illegal to use the US regulated version of the mifold Grab-and-Go booster seat on a regular basis 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 Grab-and-Go booster seat being shipped to consumers outside of the US market.  Doing so creates substantial liability to any US based retailer supplying product to non-US based addresses and consumers.

Background

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 a completely different version of mifold for the USA, compared to mifold produced for the rest of the world (RoW). The US product not only has different safety labeling and user instructions, but the physical product is a different size as well.  The US version is regulated according to the NHTSA standard FMVSS213. The RoW version is larger in size, to comply with specific United Nations requirements under the UN regulation ECE R44/04 that are not relevant under FMVSS213.

THE US VERSION MIFOLD IS ONLY TESTED TO THE US STANDARD. WE HAVE NEVER CONDUCTED ANY REGULATORY SAFETY CRASH TESTS OF THE US VERSION UNDER ANY OTHER STANDARD. WE HAVE NO DATA ON THE PERFORMANCE OF THE US PRODUCT UNDER ANY OTHER TEST STANDARD IT IS NOT CERTIFIED FOR SALE IN ANY OTHER COUNTRY EXCEPT THE UNITED STATES. IT IS THEREFORE ABSOLUTELY ILLEGAL FOR THE US VERSION TO BE USED ON A REGULAR BASIS OUTSIDE OF THE USA IN TERRITORIES THAT HAVE DIFFERENT REGULATORY STANDARDS. IN THE INTERESTS OF PUBLIC SAFETY, OUR POLICY IS NOT TO PERMIT US RETAIL PARTNERS TO SHIP THE US REGULATED VERSION OF THE MIFOLD SEAT OUTSIDE OF THE USA UNDER ANY CIRCUMSTANCES.

Correct usage, instructions and warnings

Safe use of all CRS is heavily dependent upon correct usage and installation.  This is true for all CRS, however it is especially relevant for mifold, which is a unique and innovative product that works 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, sewn-in labels and warning labeling.  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; 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 operates, we provide local labeling and instruction language combinations, even if not required by the law. This is our commitment to child passenger safety and is a public safety issue. The US version mifold only carries instructions and labelling in English and Spanish tailored specifically for the US market and for US regulations.

Recalls

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 operate, we implement a local language recall processes, even if not required by the law.  This is our commitment to child passenger safety and is a public safety issue.

We only manufacture the US version of the mifold seat 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 and Spanish in the USA. International delivery of US mifold product 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 remedy the 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 RETAILER THAT SUPPLIES PRODUCT KNOWINGLY TO NON-US ADDRESSES AND CONSUMERS.

If you would like to discuss this policy in any further detail, please do not hesitate to contact me directly.

Thank you for your ongoing support,

Jon Sumroy

CEO