Proposal to clarify the conditions under which Enhanced Child Restraint Systems must be tested in a vehicle body shell.
24. The expert from CLEPA introduced ECE/TRANS/WP.29/GRSP/2023/38 with a presentation (GRSP-74-36): to reinstate the reference to the one-belt route for installation of boosters (paragraph 6.1.3.4. of the UN Regulation) and to clarify the choice of the dynamic test on a vehicle body shell or on the test bench. The expert from the Netherlands fully supported the proposal which clarified and solved grey areas, so as to provide a full understanding of testing procedure for technical services. GRSP adopted ECE/TRANS/WP.29/GRSP/2023/38 not amended. The secretariat was requested to submit the proposal as draft Supplement 11 to the 03 series of amendments and Supplement 1 to the 04 series of amendments to UN Regulation No. 129 to the June 2024 sessions of WP.29 and AC.1.
25. The expert from CLEPA introduced GRSP-74-03 that sets strict design requirements to reduce misuse of type-approved Child Restraint Systems (CRS) already on market that had features that were not allowed by UN Regulation No. 129. He requested feedback from the experts on what can and should be done. The expert from Finland informed GRSP that when a situation of this kind occurred in his country, market surveillance intervened to withdraw the product from the market. GRSP agreed to keep GRSP-74-03 on the agenda of the May 2024 session of GRSP for further consideration.
53. The representative of the United States of America, on behalf of the Chair of GRSP recalled that Supplement 10 to the 03 series to UN Regulation No. 129 (ECE/TRANS/WP.29/2023/120) to clarify the existing requirement on “one-belt route”, adopted by WP.29 at its November 2023 session, needed further guidance. He explained that this clarification through the supplement would lead to uncertainty on previous type approvals granted in the same series of amendments but based on different interpretations and the same uncertainty would be reiterated for extensions of these type approvals preceding the supplement. GRSP experts were requested to provide feedback for discussion to Type Approval Authority Meetings (TAAM) and to be increasingly vigilant on this type of matters.
54. The representative of CLEPA stated that at the December 2023 session of GRSP, his organization highlighted through GRSP-74-03 examples of CRS on the market that would not comply with several important requirements of UN Regulation No. 129 on enhanced child restraint systems. This included, but was not limited to, violation of the requirement for only one seat belt route for installation of CRSs in a car. He underlined that CLEPA demonstrated those CRS have been type-approved incorrectly but they have a significant advantage in the market because they could offer attractive features that are not permitted to the detriment of manufacturers that respect the type-approval rules. Finally, he stated that this was a market-surveillance problem and also a type-approval problem, and actions should be taken to resolve it particularly in light of the provisions for non-conforming products under the 1958 Agreement. He concluded inviting all contracting parties to liaise with CLEPA and discuss this issue at the May 2024 session of GRSP in order to resolve it. WP.29 endorsed the approach suggested by the representative of CLEPA.