Cover was on (but the cover is extremely thin), and it does have EPS foam behind child's back and head, and on the sides of the headwings. I put a picture of it in
the naked carseat thread. I only did very rough measurements.
I just looked it up. The minimum shell height for a restraint with a weight limit below 18 kilos (39.68 pounds) is 500 mm (19.69"); restraints with a weight limit of 18 kilos and up is 560 mm (22.05 inches). All restraints must be at least 8 inches wide, measured at the height above (either 500 or 560 mm). And any headwings or side wings must either be less than 4 inches deep, or more than 6. Oh, and it specifies "padded surface," which means measuring with cover and EPS foam.
OK, I just measured again. It's 20 inches tall with the headrest all the way up (adjustable back model). And it's only 5 inches wide at that point. The widest point between the headwings (measuring at the tips of the wings) is 8.5 inches wide. The main body part of the restraint is 11 inches wide. The headwings are definitely less than 4" deep.
Measuring with the adjustable back all the way down (so I'm measuring the outer shell, not the inner shell and EPS foam), it's the same 20 inches tall. At about 19.5 inches, it is 8 inches wide. That must be how they satisfied those measurements requirements. And the sides of the outer shell are definitely in the over-six-inches category for depth.