CLEPA response to the presentation on the phase 1, 2, and 3 amendments to UN R126 (document GRSP-61-28) regarding the proposals for amendments to the 01 and 02 series of amendments and for the 03 series of amendments. CLEPA expresses concern that certain restrictions and requirements have been proposed without adequate research and discussion, often related to concerns raised under UN R44, that would imposed unwarranted burdens on manufacturers.
35. The expert from France, Chair of the IWG on Enhanced Child Restraint Systems (ECRS), gave a presentation (GRSP-61-28) on the work progress of the IWG on amendments to the UN Regulation. He explained that ECE/TRANS/WP.29/GRSP/2017/15 and ECE/TRANS/WP.29/GRSP/2017/16 were aimed, amongst others, at introducing provisions for ECRS equipped with impact shields as such restraint systems were not yet covered by the 01 and 02 series of amendments. The expert from CLEPA gave a presentation (GRSP-61-33) showing concerns on the proposals tabled by France. The expert from OICA raised concern on the increased head excursion (840 mm) during the dynamic test on rearward-facing CRS. The expert from France finally introduced GRSP-61-15-Rev.1 and GRSP-61-16-Rev.1 superseding respectively ECE/TRANS/WP.29/GRSP/2017/15 and ECE/TRANS/WP.29/GRSP/2017/16 and including the comments received. GRSP adopted ECE/TRANS/WP.29/GRSP/2017/15 and ECE/TRANS/WP.29/GRSP/2017/16 as amended by Annex VI to this report. The secretariat was requested to submit the proposals for consideration and vote at the November 2017 sessions of WP.29 and AC.1 as part (see para. 34 above): (i) draft Supplement 3 to the 01 series (ECE/TRANS/WP.29/GRSP/2017/15) and (ii) Supplement 2 to the 02 series of amendments to UN Regulation No. 129 (ECE/TRANS/WP.29/GRSP/2017/16).