NHTSA Audit Query AQ24001

The Office of Vehicle Safety Compliance (OVSC) has been evaluating a product marketed and sold by Evenflo Company, Inc. ("Evenflo") as a “Rotational All-in-One Convertible Car Seat,” under the model name “Revolve360,” based on concerns about the product’s compliance with the FMVSS for child restraint systems FMVSS No. 213 (49 C.F.R. § 571.213). The Revolve360 has a detachable base, which OVSC understands was used by Evenflo in certifying compliance with FMVSS No. 213. As documented in a test report, the Revolve360 appears not to comply with a number of FMVSS No. 213 requirements, including but not limited to the means of installation in S5.3.2 and labeling requirements in S5.5. Other similar Revolve360 products, which also use detachable bases, appear to pose the same issues with the FMVSS No. 213 requirements. Evenflo has continued to certify and offer the Revolve360 products for sale. NHTSA is aware of at least six crash incidents in the field during which the Revolve360’s shell, as referred to by Evenflo on the Revolve360’s printed instructions, reportedly separated from its detachable base. Further examination of Evenflo’s certification of the Revolve360 products as compliant with FMVSS No. 213 is necessary. Through this investigation, the agency will obtain additional information about the potential separation of the Revolve360’s shell from its detachable base to assist with the agency’s evaluation of these products.