CLEPA supports the general approach in the current draft UN R for children left in vehicles regulation. Systems shall detect presence of children through a technology neutral approach based on performance requirements. Door-logic based systems have known weaknesses and are insufficient as standalone solutions. Systems shall appropriately address situations where children are unknowingly or knowingly left in vehicles, with suitable test cases covering real-life relevant situations and child restraint system installations. CLEPA proposes replacing references to in-direct plus or direct sensing systems with sensing system throughout the regulation.