GRSP-79-17
UN R22: Comments on GRSP-79-05

Italy opposes GRSP-79-05 proposal to delete paragraphs 15.1.2 and 15.1.3 of transitional provisions, which would permit production and marketing of helmets to the earlier 05 series of amendments to UN R22. Italy argues restoring approval for UN R22.05 helmets would set technical requirements back 26 years, disrupt markets with obsolete products, penalize companies investing in UN R22.06 adaptation, and frustrate safety improvements. No appreciable price difference exists between UN R22.05 and UN R22.06 helmets, negating cost justification.

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Excerpts from session reports
GRSP | Session 79 | 1-5 Jun

15. The expert from the Kingdom of the Netherlands introduced informal document GRSP-79-05 to delete transitional provisions 15.1.2. and 15.1.3. from UN Regulation No. 22, on the basis that they contradicted article 12.4. of revision 3 of the 1958 Agreement. The expert from Italy introduced informal document GRSP-79-17 arguing that it was desirable to prevent the type approval of helmets under the preceding series of amendments to limit their presence in the market and that helmets of the 06 series of amendments were not more expensive than those of the 05 series of amendments. The expert from the Kingdom of the Netherlands pointed out that article 15.1.4. of UN Regulation No. 22 already allowed Contracting Parties to prohibit the sale of helmets from preceding series of amendments 36 months after the official date of entry into force, and added that helmets of preceding series of amendments should be kept out of the market through effective market surveillance.

16. The expert from the Russian Federation supported deleting the transitional provisions to avoid having a contradiction between the two legal texts. Given the opposing views on the matter, GRSP considered taking a vote on the proposal, but the experts from Germany and Sweden preferred to have complete clarity on the correct interpretation of the current contradicting provisions before taking a decision. GRSP recalled that in its previous session it had concluded that “in case of contradiction between the provisions of revision 3 of the 1958 Agreement and those of UN Regulation No. 22, the provisions of the 1958 Agreement should prevail” but that this report had not yet been endorsed by WP.29.