Unfortunately I've read this is variable and depends on your contact at licensing, the reasoning and such. When these rules were made this product didn't exist. They can't change really reprint all the regs and make changes based on 1 product. I was told you're not allowed to use basinets and this would be considered the same as that and not allowed BUT someone said their licensor okay'd it with a doctors note for a baby's reflux.
And yes, another part of the gray area is the straps. It's a misuse of the product to not use the buckles but it's against regs to buckle a baby in something "to sleep" in. It's not like a small infant could get out ion their own n a fire anyway, but an older child "buckled/strapped in" is sadly misused by some and prohibited.
I had one for my DS and I loved it! It would be a really great addition to infant care if used properly.

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