Combi, a worldwide leader in innovation for childcare products including car seats, supports the concept of raising the bar for child passenger safety. At the same time, Combi fully recognizes the National Highway Traffic Safety Administration (NHTSA) standard for car seats as a stringent standard that has been extremely successful in bringing car seats to the market that have provided a high level of crash protection in real world crashes.

Combi USA fully supports the findings of the NHTSA under 68 Fed. Reg. at 37622.

“NHTSA has determined that child restraints are highly effective in reducing the likelihood of death and or serious injury in motor vehicle crashes. 68 Fed.Reg. 37620, 37622 (June 24, 2003).” *

NHTSA has noted that an increase in severity of speed would require redesign of many child restraints without proportionate safety benefits 68 Fed. Reg. at 37640.

Consumer Reports’ testing appears to be aimed at raising the bar for child passenger safety and may be a starting point, however these tests cannot be considered viable for improving overall child passenger safety without thorough review and evaluation for the effects these tests would have on the design, performance, installation and ease of use of car seats.

Without additional information and proper analysis of the test protocol and actual test data, Combi USA cannot properly comment regarding the performance ratings listed within the Consumer Reports’ article. Combi USA will contact Consumers Union in an attempt to work together, as we have in the past, so we can further analyze the information from the “Crash Protection” characteristics as well as the “Ease of Use” and “Fit to Vehicle”.

All Combi car seats, including the Combi Centre, meet or exceed the applicable safety standards governed by the NHTSA. From tests conducted during the development stage to ongoing production compliance testing required by our quality standards, we have conducted over 150 dynamic tests (as specified by FMVSS 213) on the Combi Centre. All Combi car seats have passed the Federal requirements and have also passed the stringent Combi quality standards for ongoing testing of production.

Combi USA, Inc is and will continue to be dedicated to improving child passenger safety.

* Excerpt from the JPMA response to the Consumer Reports Article dated 1/4/07