34. The expert from the Netherlands, on behalf of the Technical Services Group, introduced ECE/TRANS/WP.29/GRSP/2023/11 and GRSP-73-14-Rev.1 amending it, to clarify the single belt route principle in paragraph 3.2.2. of the UN Regulation. GRSP adopted ECE/TRANS/WP.29/GRSP/2023/11 as amended by annex VIII to the session report, and requested the secretariat to submit it as draft Supplement 10 to the 03 Series of Amendments and as part of (paragraph 33) the draft 04 series of amendments to UN Regulation No. 129 for consideration and vote at the November 2023 sessions of WP.29 and AC.1.

35. GRSP considered ECE/TRANS/WP.29/GRSP/2023/14 on prevention of green indicators suggesting a belt route outside the remit of the type-approval. GRSP adopted ECE/TRANS/WP.29/GRSP/2023/14, as amended below, and requested the secretariat to submit the proposal as part of (paragraphs 33 and 34 above) draft Supplement 10 to the 03 series of amendments and to include it into (paragraphs 33 and 34) the draft 04 Series of Amendments to UN Regulation No. 129 for consideration and vote at the November 2023 sessions of WP.29 and AC.1.

The title, amend to read:
“Proposal for Supplement 10 to 03 Series of Amendments and 04 Series of Amendments to UN Regulation No. 129 (Enhanced Child Restraint Systems)” **

** Note by the secretariat: The change of the title was agreed with the author of the proposal to include the text of the draft Supplement 10 to the 03 Series of Amendments into the draft 04 Series of Amendments to UN Regulation No. 129.

34. The expert from the Netherlands, on behalf of the Technical Services Group, introduced ECE/TRANS/WP.29/GRSP/2023/11 and GRSP-73-14-Rev.1 amending it, to clarify the single belt route principle in paragraph 3.2.2. of the UN Regulation. GRSP adopted ECE/TRANS/WP.29/GRSP/2023/11 as amended by annex VIII to the session report, and requested the secretariat to submit it as draft Supplement 10 to the 03 Series of Amendments and as part of (paragraph 33) the draft 04 series of amendments to UN Regulation No. 129 for consideration and vote at the November 2023 sessions of WP.29 and AC.1.

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.

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.

26. The expert from the Netherlands introduced GRSP-74-10 which requests guidance on Supplement 10 to the 03 series to UN Regulation No. 129 (ECE/TRANS/WP.29/2023/120). He explained that the proposal had been adopted by WP.29 at its November 2023 session to clarify the existing requirement on “one-belt route”. He recalled to GRSP that the proposal aimed for a better understanding of Type Approval Authorities to guarantee a prevention of misuse by end-users of the product. He added that introducing clarification through the supplement would lead to uncertainty on previous type approvals granted in the same series of amendments but based on different interpretations. He added that the same uncertainty would be reiterated for extensions of these type approvals preceding the supplement. He therefore requested experts to provide feedback for discussion to Type Approval Authority Meetings (TAAM). The expert from CLEPA confirmed the relevance of this issue for GRSP. GRSP recommended its experts to be increasingly vigilant on this type of matters. The Chair of GRSP was requested to highlight this issue in his intervention at the March 2024 session of WP.29.