Law & Order

Federal Standards Apply to Aftermarket Head Restraints With Audio/Video Equipment

By SEMA Washington, D.C., Staff

It is illegal to market a product that does not comply with a Federal Motor Vehicle Safety Standard (FMVSS) or would take the vehicle or item of equipment out of compliance with the standard after it is installed. This requirement includes aftermarket head restraints that are outfitted with audio and video components. When installed, the restraint must continue to comply with FMVSS No. 202a (head restraints). Companies that violate any safety standard may be subject to significant civil penalties and other enforcement actions. 

Many aftermarket parts are regulated directly or indirectly by the National Highway Traffic Safety Administration (NHTSA). The FMVSS establishes minimum performance requirements without dictating design specifications. They cover basic safety equipment (e.g. tires, headlamps/taillamps, brake hoses, etc.) and establish vehicle crash-worthiness requirements (front, rear and side impact, etc.).

FMVSS No. 202 was established in 1971 to help reduce the frequency and severity of whiplash injuries. It applies to all vehicles weighing 10,000 lbs. or less. NHTSA updated the rule effective September 2009 (FMVSS No. 202a) to establish a higher minimum height requirement, limit the distance between the back of an occupant’s head and the restraint and limit the size of gaps and openings within head restraints. The rule established new strength and dynamic compliance requirements and amended most existing test procedures. The rule established requirements for head restraints voluntarily installed in rear outboard designated seating positions. 

SEMA’s Government Affairs Office has compiled a comprehensive guide on how aftermarket motor-vehicle equipment is regulated by the federal government. The guide is generally presented in a Q&A format, with links to online resources for more information.  

To learn more about FMVSS No. 202a or any other federal regulations, contact Stuart Gosswein at