Comments submitted by Israel on behalf of an association of motorcycle helmet communications equipment manufacturers.
14. The expert from Israel introduced a presentation (GRSP-67-09-Rev.1) explaining the point of view of the “motorcycle helmet communication” industry on the 06 series of amendments to the UN Regulation adopted by WP.29 at its June 2020 session. He clarified that the industry supports a UN Regulation which ensures motorbike rider safety. However, he argued that it should be implemented in a practical manner since the revised paragraph 22.214.171.124.5. of the UN Regulation requires that only accessories tested during the type approval procedure of the helmet could keep the type approval validity. He clarified that this requirement would create major trade barriers for the motorcycle helmet communication systems commonly used by motorbike riders. He therefore asked that the motorcycle helmet communication industry be included in the process of developing type approval requirements to overcome the trade barrier issue by: (a) specific tests for helmets ready for accessories, b) particular tests for communication accessories. Finally, he offered his expertise to develop amendments to consider aftermarket accessories. The expert from Italy, Chair of the IWG on Protective Helmets (IWG-PH), clarified in a presentation (GRSP-67-25) that the activities of the group were open to all stakeholders. Moreover, he added that UN Regulation No. 22 refers specifically to type approval of helmets and that the helmet manufacturer (type approval holder of a type protective helmet) is responsible for the conformity of the product and for the maintenance of the safety requirements tested during the type approval. He explained that the possible non-conformity of helmets, caused by installation of untested aftermarket products, would introduce liability issues.
15. GRSP noted that the IWG activities were suspended due to the lack of research results that would allow Phase 2 of the UN Regulation to begin. Therefore, GRSP endorsed the recommendation of the Chair of the IWG to provide a proposal of amendments addressing aftermarket accessories by the December 2020 session of GRSP. Finally, GRSP noted the offer of the expert of the United States of America to provide research results from NHTSA to the IWG once NHTSA had resumed its activities.