Proposal for the 03 series of amendments (Phase 3) to UN Regulation No. 129
Document GRSP/2017/41
24 November 2017

Formal proposal for the “Phase 3” amendments (universal belted and specific-to-vehicle belted CRS) prepared by the CRS informal group.

Submitted by France
Status: Superseded
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Previous Documents, Discussions, and Outcomes
4.6. | Consideration of draft amendments to existing UN Regulations submitted by GRSP

79. The World Forum considered the draft amendments under agenda items 4.6.1 to 4.6.8, and recommended their submission to AC.1 for voting.

80. The Chair of GRSP presented proposals on ECE/TRANS/WP.29/2018/44 and ECE/TRANS/WP.29/2018/45 under agenda items 4.6.9 and 4.6.10, to amend UN Regulations No. 14 and No. 129, in the spirit of providing the highest level of safety for children.

81. The proposal on amendments to UN Regulation No. 129 was commended by CI as the last phase for a full replacement of UN Regulation No. 44, which had not been designed to fully avoid the wrong use of child restraint systems. He recalled that the shortcomings of UN Regulation No. 44, had been raised by consumer groups ten years ago which had led to the decision to stop further developing UN Regulation No. 44 and to start a new UN Regulation. He declared that his organization and ANEC were satisfied by UN Regulations No. 129 that entails not only better protection of children, but makes Child Restraint Systems (CRS) easier to use. He expressed his thank to all the stakeholders involved, and in particular Mr. P. Castaing, Chair of the IWG, for their contributions to this result. He recommended the phasing out of UN Regulation No. 44 as early as possible to avoid confusion among consumers and allow only UN Regulation No. 129 that offers the highest level of protection. He clarified that since 1 September 2017, integral ISOFIX CRS were no longer approved under UN Regulation No. 44, and this would be the case also for non-integral Group 2 and Group 2/3 seats from 1 September 2019. Finally, he announced that for belted integral systems his organization would submit a proposal at the GRSP 2018 December session to stop type approvals according to UN Regulation No. 44.

4.6.10. | Proposal for the 03 series of amendments to UN Regulation No. 129 (Enhanced Child Restraint Systems)
17. | Regulation No. 129 (Enhanced Child Restraint Systems)

32. The expert from CLEPA introduced GRSP-62-23, clarifying the test provisions of the toxicity of materials in the UN Regulation. GRSP adopted the proposal as reproduced in Annex VII to the session report. The secretariat was requested to submit it for consideration and vote to the June 2018 sessions of WP.29 and AC.1 as part of (see paras. 29 and 31) draft Supplement 3 to the 02 series of amendments to UN Regulation No. 129.

33. The expert from France, Chair of the IWG on Enhanced Child Restraint Systems (ECRS), gave a presentation (GRSP-62-28) on the work progress of the draft 03 series of amendments to the UN Regulation (ECE/TRANS/WP.29/GRSP/2017/41). He also introduced GRSP-62-20, covering definition and provisions for lower tether strap and lower tether anchorages. ECE/TRANS/WP.29/GRSP/2017/41 received several comments and amendments including transitional provisions that were adapted according to ECE/TRANS/WP.29/2017/107. GRSP adopted ECE/TRANS/WP.29/GRSP/2017/41 as amended by Annex VII to the session report. The secretariat was requested to submit the proposal as draft 03 series of amendments to UN Regulation No. 129 for consideration and vote at the June 2018 sessions of WP.29 and AC.1. GRSP requested the secretariat to distribute GRSP-62-20 with an official symbol at the May 2018 session of GRSP.

22. | Collective amendments to Regulations Nos. 16, 44, 94, 129 and 137
17. | Regulation No. 129 (Enhanced Child Restraint Systems)

36. The expert from France introduced GRSP-61-17-Rev.2, superseding ECE/TRANS/WP.29/GRSP/2017/17 aimed at introducing the third phase of the UN Regulation which is meant to introduce “Universal belted” and “Specific vehicle belted” category of CRS. He further explained that the basic principle of Phase 3 was to reach a compromise from misuse and bad installation and having as much as possible seat places to install CRS where ISOFIX anchorages cannot be allocated. Moreover, GRSP noted the request of guidance to Contracting Parties proposed in GRSP-61-28 concerning: (i) which kind of combinations of ECRS should be allowed (e.g. ISOFIX and Universal Belted) (ii) under which conditions and (iii) guiding principles. The expert from the Netherlands raised concerns on “inserts” used on CRS to adapt them to the size of the occupant. He stated that inserts should be identified (labelled with identification and with size information) and that requirements should be devised to prevent camouflage of bad CRS. The expert from the United Kingdom supported the principle of a performance-based approach and requested more data on misuse. However, he shared the concern of the expert from the Netherlands. The expert from IC stated that ISOFIX had the priority to avoid misuse while other solutions and combinations with ISOFIX were just secondary and should be limited. The experts from Germany and Sweden raised a study reservation and stated that “plug-and-play” solution was the key principle for having a simple and efficient system; while now the ECRS IWG was opening to combinations that could have misuse implications.

37. GRSP agreed to resume discussion on Phase 3 of the UN Regulation at its December 2017 session on the basis of more data analyses. In the same time, GRSP referred back to the IWG GRSP-61-17-Rev.2 and invited representatives of Contracting Parties of the 1958 Agreement to participate in the 21-22 June meeting of the IWG to cover the request of guidance mentioned above.

22. | Collective amendments to Regulations Nos. 16, 44, 94 and 129
23. | Collective amendments to Regulations Nos. 44 and 129
Related and Previous Documents
GRSP/2017/xx
GRSP-61-17/Rev.2
CRS-67-02/Rev.1
GRSP-62-20
GRSP-62-23
GRSP-62-30
WP.29/2018/45
Relates to UN R129 |