Car Seat on a Plane: The Label, the Seat and the Rules

A child under two can fly on a parent's lap for free, and most do. The rule that allows it is a single clause in the federal operating regulations for airlines, and it has been argued over for more than forty years. The National Transportation Safety Board has recommended since 1979 that the FAA require children under two to ride in a restraint in their own seat. The FAA has never made that a requirement. What it has done is write down, precisely, which child restraints may be buckled into an airline seat, where they may go, and what the airline owes you if yours does not fit.

That second set of rules is the useful one, because it is the part a parent can act on at the gate. Most of it lives in 14 CFR 121.311 and in FAA Advisory Circular 120-87C, a guidance document written for airline crews. Both are public, and both are more specific than the advice that usually circulates.

Why a seat at all

The case for buying the extra ticket is not made by car seat brands. It is made by the NTSB, the FAA and the American Academy of Pediatrics, in almost the same words.

The NTSB's safety alert on child passengers states the problem plainly: adults may not be able to keep a secure hold on a lap-held child during turbulence or a survivable accident, and preventable deaths and injuries have occurred in unrestrained children under two. The FAA's own tip sheet says the safest place on an airplane for a child under two is in an approved child car seat or device based on the child's weight. The AAP's HealthyChildren site answers the question "Should my baby sit on my lap during the flight?" with "The short answer is no," and names turbulence as the leading cause of children's injuries on airplanes.

None of the three says a lap child is illegal. All three say the same thing about which option is safer, and that is as far as the evidence goes. The rest of this guide assumes you have bought the seat and want it to go in without an argument.

The label, word for word

Everything at the aircraft door turns on a sticker. Under 14 CFR 121.311(b)(2)(ii)(B), a seat manufactured to U.S. standards on or after February 26, 1985 must carry two statements:

1. "This child restraint system conforms to all applicable Federal motor vehicle safety standards"
2. "THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT", in red lettering

The advisory circular notes that the two are usually merged onto one label. The circular tells crews that an approved seat must have a label showing approval for aviation use, so the red line is the one to find on your own seat before you leave the house.

The reason one seat can carry both approvals goes back to the early 1980s. Aircraft restraints and car restraints were once certified to two different standards. After an NTSB recommendation in 1983, the FAA and NHTSA agreed on a single performance standard, FMVSS 213, administered by NHTSA, covering restraints for use in both. That is why an ordinary rear-facing infant seat or convertible can be legal in the cabin with no extra certification at all.

Seats from outside the U.S. are not shut out. The same regulation accepts a seat bearing a label showing approval by a foreign government, or showing that it was made to United Nations standards. The circular illustrates the UN mark as a circled "E" followed by a number identifying the approving country.

A worn or missing label. The circular covers this case directly. A seat whose label has worn off or become unreadable can still be accepted if it comes with a letter or document from the manufacturer tying that make and model to aircraft approval, and an owner's manual is also acceptable proof. If your seat is a hand-me-down with a faded sticker, pack the manual.

What is not allowed during takeoff and landing

This is the list that surprises people, because several of the items on it are perfectly good car products.

Under 121.311, booster-type restraints, vest- and harness-type restraints and lap-held restraints are not approved for use in aircraft unless the FAA has approved that specific device through its own processes. The FAA tip sheet puts the practical version in one line: baby carriers, booster seats and backless child restraints are not allowed during ground movement, takeoff or landing.

Backless boosters. The circular explains why. FAA crash research found that a backless booster on an airline seat combines two problems: the airline seat back can break forward, and an adult seated behind can load it, which can expose the child to abdominal injury. The FAA's view is that a child big enough for a backless booster can be restrained by the aircraft lap belt.

High-back boosters. These depend on whether the seat has its own harness. A seat marketed as a "booster" that has a solid back and an internal harness can carry the aircraft label and may be used for all phases of flight. A booster without an internal harness is, per the circular, labelled under FMVSS 213 as not certified for use in aircraft. If your child has moved to a belt-positioning booster, the booster stays home or goes in the hold. The age and fit test for that stage is in when to move from a booster to a seat belt.

Belly belts and soft carriers. A belly belt, a loop that straps the child to the adult's own lap belt, is on the prohibited list. The circular describes FAA crash tests in which the adult dummy pitched forward and crushed the child dummy against the seat back in front. Baby carriers are on the FAA tip sheet's list of items not allowed for takeoff and landing.

During cruise, the rules loosen. The circular states there is no regulatory prohibition on any type of child restraint during the cruise portion of a flight. It also states that airlines are free to ban non-approved devices in cruise if they choose, so check the carrier's policy rather than relying on the gap.

The one harness that is approved

The exception to the harness ban is the AmSafe CARES device, part number 4082. The circular names it as the only child restraint that may carry a label showing FAA approval under 14 CFR 21.8(d). It is a harness with a strap that encircles the airline seat back.

The FAA tip sheet gives its limits: children who weigh between 22 and 44 pounds and are up to 40 inches tall. The AAP gives the same 22 to 44 pound range and adds the part that matters most: it is not safe for car or train travel, only flying. That is the trade. CARES is a set of straps rather than a shell to carry through the terminal, and you still need a car seat at the other end.

It is also the one device the circular flags for seat-shape problems. Its upper strap may not reach around some sleeper seats or very large first-class seats, and on seats with a recessed tray-table cavity the strap has to go over both the seat back and the stowed tray table.

Where the seat can go

A restraint goes in a forward-facing airline seat, installed in the direction its own label calls for, rear-facing or forward-facing for the size of the child. The AAP is specific that a child should ride rear-facing or forward-facing on the aircraft exactly as the seat's manual says for that child in a car. If the seat and child are still rear-facing at home, they are rear-facing on board. How long that stage lasts is in how long rear-facing.

The circular sets out the placement logic crews work from:

• Window seat first. It is the preferred location because the seat cannot block anyone's path to the aisle. The FAA tip sheet says car seats generally must go in a window seat.
• Not the aisle. An aisle seat is the placement with the highest risk of slowing an evacuation.
• Not an exit row, and airlines may also bar the rows directly in front of and behind an exit, depending on how that aircraft's evacuation procedure works.
• With two children, the seat can go somewhere other than a window as long as it blocks no one's route to the aisle and the adult can reach the child to release them.

The circular also carries a warning worth knowing before you board. Some airline seats have inflatable seat belts, and a seat belt extender must always be used when a child restraint is installed in one, because the extender disables the inflation. The circular states that skipping the extender with a restraint in that seat can result in death or serious injury. Ask the crew whether your row has them.

Will it physically fit

This is the real question for most families, and the regulation helps more than people expect.

Airlines have to publish seat widths. Under 121.311(k), carriers operating under part 121 must make available on their websites the width of the narrowest and widest passenger seats in each class of service for each aircraft type. Width is defined as the distance between the inside of the armrests. That number, set against the widest point of your seat's base, is the check to do at home. The same approach to measuring a car seat against a tight space is in will this car seat fit my car.

If it does not fit, the airline must move you, not refuse you. This is the most useful paragraph in the whole circular. An airline may not prohibit a child from using an approved restraint when a seat has been purchased for the child. If the restraint does not fit a particular seat, the airline is responsible for accommodating it in another seat in the same class of service. The circular gives two examples:

1. A seat whose base is too wide for a row with rigid armrests can move to a seat with armrests that lift.
2. A rear-facing seat that cannot be installed because of minimal pitch between rows can move to a bulkhead row or a row with more pitch.

Prohibiting a restraint when there is a seat in the same class where it could be used safely is, in the circular's words, not consistent with the requirements of part 121.

The limit on that promise. It only applies to a ticketed seat. The circular says airlines are encouraged to let families use an empty seat for a restraint but are not required to let a non-ticketed child occupy one, even with an approved seat. The AAP's suggestion for families who skip the ticket is to ask the airline about using an empty seat and to fly on days and at times when air travel is lightest.

At the gate and on board

Board early. The AAP advises taking the family pre-boarding call, because the seat installs with the aircraft lap belt and the extra time keeps the aisle clear.

The crew has the final check. The regulation puts the responsibility on the airline to confirm that the restraint is properly secured to a forward-facing seat, that the child is properly secured and within the seat's weight limit, and that the label is present. Expect a flight attendant to look for the red text.

The accompanying adult. A child in a restraint must be accompanied by a parent, guardian or designated attendant, and the circular reads "adult" in 121.311 in the ordinary sense of a person 18 or older.

If you check it instead. The AAP notes that car seats, booster seats and strollers generally are not counted as luggage and can often be checked at the gate, usually at no extra cost, but that airline policies change often. How strollers and seats are treated at the gate, airline by airline, is in will my stroller fit in the overhead bin. When a restraint is on board but not in use, the circular treats it as carry-on baggage and expects it to be stowed accordingly.

Which seat to bring. If the choice is open, a seat that already fits your car, installs cleanly with a lap belt and is light enough to carry through a terminal is worth more on travel day than any feature. The seats we rank in the car seat roundup list the install method for each one.

Questions people actually ask

Is my car seat FAA approved?

Look for the red-lettered statement THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT on the seat's label. Under 14 CFR 121.311 that label, alongside the statement that the seat conforms to federal motor vehicle safety standards, is what makes a U.S. seat acceptable on board. If the label has worn off, the owner's manual is accepted as proof.

Can I use a booster seat on a plane?

Not a backless booster, and not a high-back booster that relies on the car's shoulder belt. Both are prohibited during ground movement, takeoff and landing. A seat sold as a booster that has a solid back and its own internal harness can carry the aircraft label and can be used for the whole flight.

Can the airline refuse my car seat?

Not if the seat is approved and you bought a ticket for the child. If it does not fit the assigned seat, the FAA's advisory circular says the airline must accommodate it in another seat in the same class of service, for example a seat with lifting armrests or a bulkhead row with more pitch.

Can my baby face backwards in the airplane seat?

Yes, if that is how the seat's manual says to install it for your child. The AAP advises using the same rear-facing or forward-facing direction on the plane as in the car. The airline seat itself must face forward.

What is the CARES harness and who is it for?

It is the AmSafe CARES device, a strap system approved by the FAA for use on aircraft only. The FAA lists it for children between 22 and 44 pounds and up to 40 inches tall. It is not approved for use in a car, so you still need a car seat at your destination.

Do I need to buy a seat for a baby under two?

No. Federal rules allow a child under two to be held on an adult's lap. The NTSB, the FAA and the AAP all say a child is safer in an approved restraint in their own seat, and only a purchased seat guarantees the airline must make room for that restraint.

Sources

• eCFR, 14 CFR 121.311, Seats, safety belts, and shoulder harnesses
• FAA Advisory Circular 120-87C, Use of Child Restraint Systems on Aircraft
• FAA, Child safety: keep your little one safe when you fly
• NTSB Safety Alert SA-015, Child passenger safety on aircraft
• American Academy of Pediatrics, HealthyChildren.org, Flying with baby