As a counterproposal to document GRSP/2017/27 submitted by the EC, OICA suggests to group all the airbag warning requirements in one single UN Regulation (i.e. UN R16); this would avoid future administrative burden when these may need adaptation. Another solution could be to simply refer, in UN R94 and UN R137, to the label defined in UN R16; OICA suggests that GRSP discusses the most suitable approach.
In addition, OICA agrees with the EC proposal to better define the required label, in order to avoid potential misinterpretations. However, when it comes to the printing of the user information in a multitude of languages, OICA considers this is an unnecessary burden, with no benefit to the user. User manuals are placed in the vehicles at the point of sale and therefore in the local language(s); in the not so frequent cases whereby a vehicle, during its lifetime, ends up in a different country/language, the user will always be able to obtain the manual in his own language, if he so asks. OICA consequently proposes not to amend the current requirements on the issue of languages.
39. The expert from OICA introduced GRSP-62-14, as an alternative proposal to ECE/TRANS/WP.29/GRSP/2017/27 tabled by the expert from EC, concerning the information in the airbag warning label on the correct installation of CRS on a passenger seat with an activated frontal airbag. He suggested that the proposal should be adopted as a new series of amendments to UN Regulation No. 16 (Safety-belts) instead of a Supplement and to regroup these kind of requirements in UN Regulation No. 16 only. He also underlined the problem of translation in all languages of the detailed information, which makes reference to the warning, that should be contained in the owner’s manual.
40. The expert from Australia explained that his country requires vehicles to be fitted with an airbag warning label through a national rule that requires vehicles to meet UN Regulation No. 94. He added that although his country also had a national rule that incorporates UN Regulation No. 16, this rule does not require vehicles to meet the airbag warning label requirements of UN Regulation No. 16. Therefore, he stated that removing the requirement for an airbag warning label from UN Regulation No. 94 would create a loophole, which would allow vehicles to be supplied to the Australian market without any airbag warning label.
41. GRSP agreed to resume discussion on this subject at its May 2018 session. The secretariat was requested to distribute GRSP-62-14 with an official symbol at the next session awaiting a possible revised proposal submitted by the expert from OICA.